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What is an external Data Protection Officer?
An external Data Protection Officer (DPO) is an independent expert whom a company contractually designates as the person responsible for operational data protection. Unlike an internal DPO, they are not an employee – they bring specialized expertise, independence, up-to-date legal knowledge, and experience, without being permanently on the payroll.
The legal basis is Articles 37–39 GDPR and Section 38 BDSG: Companies that exceed certain thresholds or process particularly sensitive data are obliged to appoint a DPO.
Who is Proliance's external DPO suitable for?
Proliance supports companies across the entire DACH region – from growing start-ups to established mid-sized businesses.
Particularly suitable for:
- SMEs (20–500 employees) that legally require a DPO but cannot justify a full-time position
- Companies without in-house compliance expertise looking for a reliable partner
- Companies in regulated industries (health, finance, HR tech) that require industry-specific expertise
- Growing companies that want to implement scalable data protection
- Companies with international ties that need to ensure GDPR compliance for cross-border data processing
When is a Data Protection Officer mandatory?
In Germany, a Data Protection Officer is legally required in the following cases:
- Ab 20 Personen, die regelmäßig personenbezogene Daten automatisiert verarbeiten (§ 38 BDSG)From 20 individuals who regularly process personal data automatically (§ 38 BDSG)
- When processing special categories of personal data (e.g., health data, biometric data) in accordance with Art. 9 GDPRVerarbeitung besonderer Kategorien personenbezogener Daten (z. B. Gesundheitsdaten, biometrische Daten) gemäß Art. 9 DSGVO
- For the commercial processing of personal data for the purpose of transmission or anonymized evaluationgeschäftsmäßigen Verarbeitung personenbezogener Daten zum Zweck der anonymisierten Übermittlung oder für Markt- und Meinungsforschung
- For certain monitoring measures (e.g., video surveillance, scoring)Überwachungsmaßnahmen (z. B. Videoüberwachung, Scoring)
Ask now for a non-binding consultation offer
Even without a DPO obligation, the GDPR remains binding
(DPO), whether it's time for a change,
and how to go about it.
What are the advantages of an external Data Protection Officer compared to an internal one?
The decision between an internal and external DPO is a strategic one. Here are the key differences at a glance:
Conclusion
What does your external Data Protection Officer handle at Proliance?
Our team of certified DPO experts handles all legally mandated and additional tasks – proactively, not reactively.
Appointment and Formal Designation
We handle the legally compliant appointment as an external DPO according to Art. 37 GDPR, including notification to the competent supervisory authority and documentation in the record of processing activities.
Consulting and Ongoing Support
Your dedicated contact person is available for all data privacy questions – from the introduction of new tools and employee inquiries to communication with authorities.
Data Protection Audits and Risk Analyses
Regular review of your processing activities, identification of risks, and development of concrete measures – documented and audit-ready in Proliance 360.
Training and Awareness
Data protection starts with people. We train your employees – digitally, efficiently, and verifiably – to prevent data breaches from occurring in the first place. → To Data Protection Training
Support with Data Breaches and Regulatory Communication
In an emergency, every hour counts. We support you with reporting data breaches (Art. 33 GDPR), communication with supervisory authorities, and documenting all measures. → To Data Protection Documentation
Contract Management and Data Processing
Review and drafting of Data Processing Agreements (DPAs) in accordance with Art. 28 GDPR – for all service providers who process personal data on your behalf.
Support for Handling Data Subject Requests
Support in implementing data subject rights: Requests for erasure, access requests, objections, and the withdrawal of consent must be processed accurately and in a timely manner to avoid complaints from supervisory authorities.
Consulting for the implementation of new IT systems and technologies
When introducing new IT systems or technologies, we help ensure a privacy-friendly design and configuration and know what it takes to legally process data.
What does an external Data Protection Officer cost?
The costs for an external DPO vary depending on company size, industry, and scope of support. As a guide:
For comparison:
- 1 user access to the Proliance 360 data protection software
- Consulting hours on request
- Up to 72-hour response time for inquiries
- Additionally, 6 user accounts for the data protection software for functional areas
- A total of 15 consulting hours from our data protection experts (per year)
- Up to 48 hours response time to inquiries
- Unlimited access
- A total of 25 consultation hours with our data protection experts (per year)
- Up to 24-hour response time for inquiries
- Dedicated contact person from our Privacy Team
With Proliance, you properly implement data protection
Without Proliance
- Legal Risk: Unclear responsibilities, missing documentation, unnecessary vulnerabilities in audits.
- Operational Risk: Data protection falls by the wayside because internal resources are lacking or priorities change.
- Knowledge Risk: Individual knowledge, dependence on one person, high onboarding and training burden.
- Communication Risk: Friction between departments, IT, HR, and management – with no neutral mediator.
- Cost Risk: Unpredictable expenses due to training, absences, and ad-hoc consulting.
With Proliance
- Team of Experts, not an Individual: Your contact person is backed by a team – ensuring backup and integrated software and consulting from a single source: Proliance 360 consolidates tasks, documents, and evidence – immediately audit-ready.
- Proactive, not reactive: We provide timely updates on changes, rulings, and specific actions required.
- Industry Expertise: Hands-on expertise from regulated industries – understandable, actionable, without buzzwords.
- Transparent Collaboration: All activities and recommendations are transparently documented – no black box.
Holistic instead of piecemeal – our data protection portfolio
After the initial assessment, it's not just about 'somehow being GDPR compliant,' but about maintaining compliance permanently: with clear responsibilities, verifiable documentation (e.g., VVT, TOMs, data processing agreements), regular training, and a system that doesn't forget updates and tasks.
How working with Proliance works
Efficient data protection starts here. We'll show you how.
What to expect in the initial consultation:
- Analysis of Your Current Data Privacy Situation
- Clarification of Legal Obligations for Your Company
- Specific Offer for Your External DPO
What 2,500+ Companies Value Most About Proliance
Frequently asked questions always need good answers. Here they are.
In serious cases – such as a data breach – we assist you with reporting in accordance with Art. 33 GDPR, communicating with the competent supervisory authority, informing affected individuals as per Art. 34 GDPR, and thoroughly documenting all actions. We also support you during official audits, for instance, following a complaint from an affected individual.
Pricing is based on company size, industry, and the scope of services required. For SMEs, packages start at €125 per month. Get a personalized quote during a free initial consultation.
Yes. Unlike an internal DPO, an external DPO does not have enhanced protection against dismissal. The contractual relationship can be terminated in accordance with the agreed terms. Proliance ensures a seamless handover.
Article 37(5) of the GDPR requires that the DPO must possess expert knowledge in data protection law and practice. All Proliance DPOs are certified (TÜV, GDD, or comparable) and continuously develop their expertise. They are supported in their work by a team of lawyers and auditors.
The service is commissioned through a written service contract. Proliance then handles the notification to the competent supervisory authority and the documentation in the record of processing activities – fully and in a legally compliant manner.
The internal DPO is an employee of the company, while the external DPO is an independent service provider. An external DPO offers specialized expertise, legally guaranteed independence, and a team of experts supporting them – all without special termination protection and without the costs of a full-time employee.
In Germany, a Data Protection Officer (DPO) is legally mandatory for organizations with 20 or more individuals who regularly process personal data automatically (§ 38 BDSG). Furthermore, a voluntary appointment can be beneficial to minimize liability risks.