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External DPO and Interim Data Protection Officer
An independent DPO who actually knows your organisation — operational from day one, no consultancy funnel. For SMEs, corporates and public sector organisations.
A Data Protection Officer (DPO) — in Dutch ‘Functionaris Gegevensbescherming’ or FG — is legally required under the GDPR for many organisations. Filling the role internally is often expensive, and the right expertise is scarce. DCBS delivers an external DPO or interim Data Protection Officer who is operational from day one, with experience at supervisory authorities, municipalities, utilities and private organisations.
An external DPO from DCBS operates with the full independence the GDPR requires. No consultancy funnel staffed with juniors, but a single point of contact who actually learns your organisation — and stays with you, even when your internal team changes.
What an external DPO delivers
Full DPO function: signalling, advising, supervising — with a direct escalation route to the Dutch Data Protection Authority. Scalable from a few hours per month to a continuous presence.
External DPO under GDPR Article 38: independent, not instructed by management, with a direct escalation line to the highest level of your organisation.
Interim Data Protection Officer during recruitment, prolonged absence or reorganisation. Operational immediately, no three-month onboarding.
Weekly presence advising project and line managers, reviewing new processing activities, monitoring breach handling and assessing DPIA outcomes.
From one half-day per month to three days per week. For SMEs that are legally required to appoint a DPO but don't yet have the scale for a full-time role.
Continuous knowledge transfer to your internal privacy team. Permanent contact point for the Dutch DPA on inquiries, complaints or inspections.
Statutory DPO requirement unmet
You are a public sector organisation or a company that structurally processes data at scale or processes special categories. A DPO is required under GDPR Article 37 but has not yet been appointed — or the existing appointment does not meet the independence requirement.
Handover after DPO departure
Your DPO is leaving and recruiting a successor takes three to six months. In the interim the DPO function must remain operational: processing records maintained, DPIA reviews completed, breach handling uninterrupted.
Capacity peak or complex programme
Your internal DPO faces an exceptional peak: implementation of a new core system, AI rollout, GDPR enforcement track by the supervisory authority, or a complex breach with board-level impact. External reinforcement for a defined phase.
Concrete deliverables
- Operational DPO or interim DPO within five working days
- One permanent point of contact — no rotating juniors
- Annual plan with priorities and quarterly board reports
- Processing records maintained, breach protocol tested, DPIA register current
- Advisory notes and escalation route to the supervisory authority
- Fixed monthly fee — no surprise hourly invoices
Four steps
- Intake & baseline — conversation with the client and current privacy stakeholders. Assessment of processing records, DPIA archive, breach procedure and any pending supervisory matters.
- Onboarding & handover — access to relevant systems, introductions to key people, formalisation of the DPO appointment and registration with the Dutch DPA.
- Operational DPO phase — fixed rhythm: weekly presence, monthly board reporting, quarterly risk review. Direct escalation in case of incidents.
- Reporting & continuous improvement — annual report to board and supervisory board. Ongoing improvement of the privacy management system; phase-out or handover on internal appointment.
Sectors where DCBS fills DPO roles
DCBS works for regulators, municipalities, utilities, insurers and private organisations. For specific case examples — see our cases.
Engage an external DPO?
Free 30-minute intake call. The conversation assesses whether there is a match and, if so, what an external DPO or interim DPO engagement could look like for your organisation.