Contents
What is DPO as a Service?
DPO as a Service (DPOaaS) is the outsourcing of the Data Protection Officer role. Instead of appointing an exclusive in house position, the organisation engages a specialist - an individual or a team - that fulfils the same obligations: providing guidance, monitoring compliance, handling data subject requests (DSARs) and acting as the main point of contact with supervisory authorities, with independence and robust evidence.
In Brazil, under the LGPD, the role is often referred to as Data Protection Officer or Encarregado de Dados. Under the GDPR in the European Union and the United Kingdom it is called Data Protection Officer (DPO). DPOaaS keeps the legal remit and autonomy of the role, while providing scale, predictable cost and access to multidisciplinary expertise.
Concept and operating model
Core responsibilities
- Governance: policies, legal bases, retention and privacy by design.
- Monitoring: RoPA, DPIA, risks and incidents.
- Handling: DSARs with SLAs, identity verification and audit trail.
- Interfaces: data subjects, supervisory authorities and due diligence processes.
Service model
- Scope and SLAs defined per contract and per client.
- Multidisciplinary team (legal, security, data).
- Indicators, reports and exportable evidence.
- Integrations with the organisation systems (CRM, support, SSO, data warehouse and more).
Brief history: how DPOaaS emerged
The DPO role gained strength with the GDPR (European regulation published in 2016 and applicable from 2018), which formalised responsibilities and expanded the requirement for the role in scenarios involving systematic monitoring and large scale processing. At the same time there was a shortage of qualified professionals and a growing need for quick and structured responses to data subjects and auditors.
In response, consultancies and law firms started to offer DPO as a service, combining regulatory expertise, standardised processes and tooling to demonstrate compliance. Adoption accelerated with technological complexity (cloud, SaaS ecosystems) and the expansion of data protection laws worldwide (such as the LGPD), consolidating DPOaaS as a sustainable model for SMEs and also for larger organisations during periods of transition.
When does DPOaaS make sense?
- Contractual requirement in RFPs, vendor due diligence or sector specific audits.
- Need for independence and mitigation of conflicts of interest.
- Operation across multiple jurisdictions or with special category or sensitive data.
- Search for scale, standardised processes and evidence ready for audits and client reviews.
How it works in practice
1) Agreement and scope
Definition of responsibilities, SLAs, communication channels and metrics.
2) Onboarding
Initial RoPA, existing policies, consent and cookie practices and DSAR channels.
3) Ongoing operation
Handling of data subject requests, identity verification, risk and incident management.
4) Evidence and reporting
Logs, exports, SLA indicators and materials for audits and due diligence processes.
Benefits and trade offs
Benefits
- Independence and continuous up to date expertise.
- Scale, faster implementation and predictable cost.
- Traceable evidence and audit ready reporting.
Trade offs
- Need for clearly defined access governance.
- Careful management of scope and expectations in contracts and SLAs.
- Effective integration with internal teams, processes and culture.
How Unova enables DPOaaS
Unova centralises the privacy operation to reduce risk, standardise workflows and demonstrate compliance with audit ready evidence:
DSARs with identity and SLAs
Verification, timelines, templates and detailed audit trail per client.
RoPA, DPIAs and policies
Mapping of processing activities, risks and controls with version history and exports.
Consents and cookies
Proof of consent, preference management and GDPR aligned banners.
Integrations and webhooks
CRM, support tools, SSO and SCIM, data warehouse and API or SDK for automation.
Reports and evidence
Exports, logs and electronic signatures for audits, client reviews and internal committees.
Data subject portal
Transparency for data subjects to track their requests, outcomes and preferences.
Frequently asked questions
Does DPOaaS replace having an internal team? +
DPOaaS can assume the formal role and operate alongside internal teams and partners. What matters is maintaining independence, clear processes and strong evidence of compliance.
Who is legally responsible before the supervisory authority? +
The organisation remains responsible for the processing of personal data. The DPOaaS provider acts as focal point, adviser and monitor, while keeping autonomy and impartiality.
How do we avoid conflicts of interest? +
Define an appropriate reporting line, separation of duties and clear internal policies. The DPO should not take decisions about processing activities that they will later review or monitor.
How long does implementation take? +
It depends on the size and maturity of the organisation. In most cases, onboarding (initial RoPA, DSAR channels and core policies) takes place in the first weeks, followed by continuous improvement and regular updates.
Ready to structure the DPO role?
Try Unova and accelerate your GDPR and LGPD compliance journey.
