Data Privacy & Information Governance
Fractional & Outsourced DPO Services
Senior DPO assurance without a full-time appointment.
Appoint independent Data Protection Officer capability that gives senior management clear advice, credible challenge and ongoing visibility of privacy risk.
IG-Smart provides fractional and outsourced DPO services for organisations that require a formal external Data Protection Officer, or need senior DPO-level capability without building a full-time internal function.
Our role is designed around independence, risk-based oversight and defensible evidence — helping leadership understand the position, make informed decisions and demonstrate accountable privacy governance.
- Independent DPO Capability
- Senior Practitioner Access
- Board-Level Reporting
- Risk-Based Oversight
- UK GDPR Focus
When organisations engage us
When organisations engage us
IG-Smart provides senior external DPO capability for organisations that need independent, experienced support without necessarily building equivalent permanent capability in-house. Not every organisation is legally required to appoint a DPO; many engage us because the role, the risk or the scrutiny they face calls for senior independent oversight.
Where a DPO is mandatory: under Article 37 of the UK GDPR, an organisation must appoint a Data Protection Officer in specified circumstances. Articles 38 and 39 then set out the DPO’s position and tasks.
Public authority or body
Except courts acting in their judicial capacity.
Large-scale regular and systematic monitoring
Where this forms part of the organisation’s core activities.
Large-scale special-category or criminal-offence data processing
Where this forms part of the organisation’s core activities.
Organisations can also appoint a DPO voluntarily.
The decision is not simply about organisation size. Relevant considerations can include the number of individuals affected, the volume and range of personal data, the geographical extent and duration of processing, and whether the relevant processing forms part of the organisation’s core activities.
For organisations that do not need a full-time internal DPO, an external appointment can provide access to appropriate expertise while preserving the independence the role requires. The ICO confirms that the DPO function can be contracted externally; an externally appointed DPO carries the same position, tasks and responsibilities as an internal appointment.
Organisations typically approach IG-Smart when:
- an independent DPO is required, or an internal appointment would create a conflict of interest;
- an existing DPO has left, or internal DPO capacity cannot keep pace with demand;
- processing has become complex or high-risk — special-category data, monitoring or new technology;
- operations span several countries, with international transfers to manage;
- regulators, customers, procurement teams or auditors are scrutinising privacy governance;
- growth, restructuring or M&A is changing how personal data is used;
- leadership needs ongoing senior privacy governance rather than one-off documentation.
What we help solve
What we help solve
No credible independent oversight
Privacy decisions are made without senior, independent challenge, or the DPO role sits with someone whose other duties conflict with it.
Capacity and continuity gaps
The DPO role is vacant, under-resourced or dependent on one person, leaving advice, DPIAs and escalations waiting.
Risk outpacing expertise
High-risk processing, international operations or new technology need more experience than a general compliance function holds.
Weak evidence of accountability
The organisation cannot readily show regulators, customers or the board how privacy risk is overseen and decided.
Independence
A DPO is independent oversight — not outsourced compliance ownership
This distinction matters. The DPO should be involved closely and in a timely manner in relevant data-protection matters, operate independently and have direct access to the organisation’s highest management level.
The Data Protection Officer advises, monitors, challenges and reports. The controller or processor remains responsible for complying with data-protection law. Appointment of an internal or external DPO does not transfer the organisation’s legal accountability to the DPO.
That principle shapes the IG-Smart service. We avoid constructing a model in which the DPO is expected to make operational decisions and then independently assure those same decisions.
Where clients also need operational privacy capacity — for example routine rights-request management, records administration, policy implementation or broader privacy-programme management — IG-Smart can scope that support separately and establish appropriate role boundaries.
Independence is designed into the operating model.
Board / Senior Management
Accountable for decisions and compliance
Independent oversight
Independent DPO
- Advise
- Monitor
- Challenge
- Report
Advises, monitors and challenges alongside — does not manage
- Legal
- Cyber Security
- HR
- Business Owners
- Procurement
- Privacy Operations
- DPO
- Advises, monitors, challenges and reports.
- Controller / processor and operational owners
- Make and own operational compliance decisions.
What the engagement involves
What the engagement involves
The DPO advises, monitors and challenges. Management decisions — and legal responsibility for compliance — stay with the organisation.
Independent DPO appointment and governance
Where IG-Smart is formally appointed as DPO, we establish the mandate, reporting relationship, escalation route and working model needed to protect the function’s independence and ensure appropriate access to senior management. The operating model also addresses the required DPO contact arrangements, including publication and regulatory notification where applicable.
Senior advice and constructive challenge
We give leadership independent, risk-based advice on material privacy decisions and emerging risks, creating a defensible record of significant advice and organisational decisions.
Compliance monitoring and privacy assurance
A proportionate monitoring programme across relevant privacy governance — from policies, records and training to high-risk processing, supplier issues and agreed privacy controls.
DPIA advice and oversight
We advise on and monitor Data Protection Impact Assessments, challenging scope, risk analysis, mitigations and residual risk while the business decision stays with the organisation.
Regulatory and stakeholder interface
Where IG-Smart is the appointed DPO, we provide the DPO contact point for the ICO and clear routes for employees and individuals to contact the DPO.
Executive and board reporting
Decision-ready reporting on privacy risk, findings, remediation and accepted residual risk — what the issue is, why it matters and who owns the decision.
Privacy risk assessment and privacy by design
Risk-based review of new and changing processing, with privacy-by-design input early enough to shape systems, suppliers and products.
Data-subject and international-transfer issues
Support on complex rights requests and complaints, and advice on international transfers where operations or suppliers sit outside the UK.
Issue escalation and decision support
A clear route for raising privacy issues, with documented advice so management can make and record informed decisions.
How we deliver
How the engagement runs
- 01
Assess
Establish why DPO capability is required, the processing and risk context, current governance, conflicts and material gaps.
- 02
Build
Define the mandate, reporting line, contact arrangements, escalation routes, priorities and monitoring plan.
- 03
Manage
Provide retained senior DPO advice, accessibility and support for material privacy decisions.
- 04
Assure
Monitor the privacy position through risk-based reviews, DPIA oversight, governance challenge and executive reporting.
- 05
Improve
Translate findings into prioritised improvements and monitor progress as privacy governance matures.
Improvement feeds the next assessment cycle, keeping the assurance position current rather than rebuilding it from scratch.
What you receive
What you receive
Depending on the agreed scope, typical DPO outputs can include:
- 01Documented advice and decision recordsA defensible record of material DPO advice, the organisation’s response and significant residual-risk decisions.
- 02Prioritised privacy actionsFindings translated into a prioritised action list with accountable owners and visible progress.
- 03DPIA review and challengeIndependent evidence of DPO involvement in high-risk processing decisions.
- 04Governance reportingDecision-ready reporting for executives and the board on material risk, trends and matters needing attention.
- 05Policy and control recommendationsPractical recommendations to strengthen policies, procedures and privacy controls.
- 06Evidence of DPO oversightA DPO mandate, operating model and work plan showing how independent oversight is exercised.
- 07Escalation and issue recordsStructured records of issues raised, advice given and, where relevant, regulatory interactions.
Scope
What is included — and what should be scoped separately?
Core DPO scope
Core fractional / outsourced DPO scope
The core service can include formal DPO appointment, statutory DPO tasks, retained advice, risk-based compliance monitoring, DPIA advice and monitoring, accessibility to relevant stakeholders, ICO liaison in the DPO capacity and executive assurance reporting.
Available separately where required
Operational privacy work
Operational privacy work can be added through the wider IG-Smart privacy service architecture, including:
- Rights-request case management
- Detailed ROPA administration
- Policy development
- Major remediation programmes
- Privacy maturity assessments
- International-transfer reviews
- Training delivery
- Extensive audit programmes
- Complex breach investigations
- Cyber incident response
- Other specialist consultancy
This prevents the DPO engagement from becoming an undefined pool of compliance hours and makes responsibility clearer for both the client and the independent adviser.
Relevant evidence
Selected DPO and privacy engagements
Published engagements where IG-Smart provided external DPO capability or senior privacy governance.
Life Sciences / Pharmaceutical, Data Privacy & DPO
Glenmark Pharmaceuticals
Retained external DPO service for a global pharmaceutical company's EU and LATAM operations
A global pharmaceutical company's legal and compliance team needed responsive, expert DPO support across EU and LATAM.
The client's VP Legal & Compliance (EU and LATAM): “Knowledgeable and responsive… We are in safe hands.”
Read the case studyRetail / Consumer, Data Privacy & DPO
Paul UK
A five-year retained DPO partnership for a bakery and restaurant chain
A growing consumer brand needed data-protection advice that translated GDPR into everyday business practice.
Client describes the report as accurate, easy to follow and intuitive.
Read the case studyFinancial Services, Data Privacy & DPO · Cyber Governance & Assurance
DAG Global (now Greengage)
Data protection by design for a start-up digital merchant bank
A start-up digital merchant bank, pursuing a UK banking licence at the time, needed data protection built into its platform before launch.
The CEO reports the advice and training helped embed robust controls into the business.
Read the case study
Common engagement models
Fractional DPO, outsourced DPO or privacy programme?
The right model depends on what the organisation actually needs.
Fractional DPO
- What is it?
- Senior DPO capacity on a retained, proportionate basis.
- When is it appropriate?
- When the organisation needs senior DPO-level capability without a full-time appointment.
- Is IG-Smart formally appointed DPO?
- Depends on the agreed engagement — documented at the outset as either a formal appointment or DPO-level advisory support.
Outsourced DPO
- What is it?
- An externally contracted DPO function.
- When is it appropriate?
- When a formal external Data Protection Officer is required or preferred, including interim cover.
- Is IG-Smart formally appointed DPO?
- Can include formal designation of IG-Smart as the organisation’s Data Protection Officer.
Managed privacy programme
- What is it?
- Operational privacy capability — implementing controls, maintaining records, coordinating activity and progressing remediation.
- When is it appropriate?
- When the organisation needs privacy work delivered, not only overseen.
- Is IG-Smart formally appointed DPO?
- Not by itself. A managed privacy programme provides operational delivery. Where IG-Smart also provides DPO services, responsibilities and decision rights are defined separately to protect DPO independence.
These can work together, but they are not interchangeable. IG-Smart defines the boundary at the outset so the DPO can retain the degree of independence necessary for credible advice and assurance.
Typical investment
Indicative investment
Outsourced / Fractional DPO
Starting investment: £2,500 + VAT per month
Typical investment: £3,000–£7,500+ + VAT per month for more complex organisations
Model: Managed & retained service
Usually increases investment: Organisational complexity and number of entities; Processing risk; Jurisdictions in scope; Required availability; Volume of rights requests, DPIAs and incidents; Board and regulator reporting requirements
Scope, deliverables, assumptions and fees are agreed in writing before work begins. What changes the fee is set out on the investment page; the exact fee is confirmed after scoping.
How engagements and investment workFAQ
Frequently asked questions
Regulatory references reviewed September 2026. This page is maintained against current UK GDPR and ICO guidance.
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Discuss a DPO requirement
Need a DPO — or still deciding what the organisation needs?
Whether you need a formal external appointment, interim DPO capability or help defining the right privacy operating model, start with the requirement.