For many small businesses, complying with the UK GDPR feels like walking a tightrope—especially when it comes to appointing a Data Protection Officer (DPO). While large organisations often have legal teams or dedicated compliance departments, small businesses are expected to meet the same strict standards with far fewer resources.
Let’s break down what the law requires—and why many small businesses are choosing to outsource the DPO role to specialists like CVG Solutions.
What the Law Requires of Your DPO
If you need to appoint a DPO under the UK GDPR there are specific expectations you must meet:
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The DPO must report directly to the highest management level of your organisation—typically your board or owner.
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They must operate independently, meaning they can’t be told how to do their job, and they can’t be penalised or dismissed for carrying out their DPO duties (though they can be dismissed for unrelated misconduct).
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You must provide adequate resources—time, training, tools, and support—so the DPO can fulfil their responsibilities effectively.
These are serious obligations. And for small businesses, meeting them can be far from straightforward.
Can You Assign the DPO Role to an Existing Employee?
Technically, yes. You’re allowed to allocate the DPO role to someone already on your payroll—as long as their other responsibilities don’t create a conflict of interest.
But here’s the challenge: in a small business, staff often wear multiple hats. Your Operations Manager might also handle HR. Your IT lead may oversee marketing systems. These overlaps can make it almost impossible to maintain the independence and objectivity required of a DPO.
What Qualifications Does a DPO Need?
There’s no official list of certifications or degrees a DPO must have. Specifically, in the UK there is no such thing as a certified DPO. However, they must have expert knowledge of data protection law and practices appropriate to the nature and scale of your data processing.
That means a DPO working with sensitive health data needs a different level of expertise than one overseeing a basic CRM. The role isn’t just administrative—it requires a solid grasp of legal, technical, and ethical issues.
For small businesses, finding an internal team member with this expertise—who’s also independent and free from conflicting duties—is often unrealistic.
Why Outsourcing Your DPO Role Makes Sense
This is where DPO as a Service (DPOaaS) from providers like CVG Solutions comes in.
Outsourcing gives you access to a qualified, independent expert who:
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Reports to your leadership and keeps you informed on risks and requirements
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Has up-to-date knowledge of UK GDPR and data protection best practices
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Helps you handle subject access requests, breaches, and impact assessments
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Offers flexible support tailored to your business size and risk level
You’ll receive the benefit of the role without stretching your internal team or budget.
Final Thoughts
The reality is, DPO requirements weren’t written with small businesses in mind. But compliance is still your responsibility, and penalties for getting it wrong can be serious.
Outsourcing your DPO role to a trusted provider like CVG Solutions allows you to meet your legal obligations confidently, without compromising on independence, expertise, or accountability. Stride forward with complete confidence that your privacy and data protection requirements are being managed.
Need support with data protection compliance? Get in touch with CVG Solutions to learn how our DPOaaS can keep your business with working toward compliance and focused on growth.
How to contact us
01775 660506
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