Virtual DPO:
Your Named DPO Without the Full-Time Hire.
A senior Data Protection Officer embedded in your organisation – registered with regulators, accessible to data subjects, and accountable for your privacy programme. Plus Article 27 EU Representative services for companies outside the EEA processing EU personal data.
Evolution of Privacy Leadership
Traditional Friction
A junior hire named as DPO with no regulatory experience and no independence from the business
Article 37 obligations met on paper but no active oversight of processing activities, DSARs, or breach response
Companies outside the EEA processing EU data with no Article 27 representative - a direct regulatory violation most don't know they have
The ATORO AI-Native Reality
A named DPO registered with your supervisory authority - senior, independent, and actively managing your privacy programme
DSAR handling, breach response coordination, DPIA reviews, and regulator liaison handled by someone who does this every day across multiple jurisdictions
Article 27 EU Representative services included for non-EEA companies - one engagement covers both obligations
System Status
Post-Friction Compliance Engine Active
The Core Framework
Appoint, Operate, Protect
Appoint
Your named DPO is registered with the relevant supervisory authority and formally appointed under Article 37. We assess your processing activities, map your data flows, and establish the governance framework your DPO role requires from day one.
Operate
Your vDPO actively manages your privacy programme – ROPA maintenance, DPIA reviews, DSAR coordination, breach response, processor oversight, and regulator liaison. Not a name on a form. An operating function embedded in your business.
Protect
When a data subject complains, a regulator inquires, or a breach occurs – you have a senior privacy professional ready to respond. Defensible processes, documented evidence, and someone who has handled this before across multiple jurisdictions.
Privacy Leadership, Without the Headcount
Technical Module 01
Active DPO Function
Not a quarterly check-in. Your vDPO monitors processing activities, reviews DPIAs before new products launch, manages your ROPA as your data landscape changes, coordinates DSAR responses within regulatory timelines, and provides the independent oversight Article 38 requires. Available when your team needs guidance, not just when the contract says so.
Zero-trust discovery protocols
Automatic tag propagation
Technical Module 02
Article 27 EU Representative
If your company is established outside the EEA but processes personal data of EU residents, Article 27 requires you to appoint an EU-based representative. We act as your designated representative – the point of contact for supervisory authorities and data subjects. Bundled with your vDPO engagement or available standalone.
"A DPO who only appears when there's a breach is not a DPO. Privacy leadership means being embedded in the decisions that create risk - product launches, new vendors, new markets, new data flows. The companies that get this right don't just avoid fines. They earn the trust that closes enterprise deals."
Thomas Mcnamara
Chief Executive Officer, ATORO
The Path to Privacy Leadership
01
Assessment
Assess your current privacy posture, processing activities, and regulatory obligations. Determine whether you need a DPO under Article 37, an Article 27 representative, or both. Map data flows and identify gaps in your privacy programme.
02
Appointment
Formally appoint your vDPO and register with the relevant supervisory authority. If needed, appoint your Article 27 EU Representative. Establish communication channels, escalation procedures, and reporting cadence with your team.
03
Ongoing Operations
Your vDPO manages ROPA updates, DPIA reviews, DSAR coordination, breach response, processor oversight, and regulator liaison on an ongoing basis. Regular reporting to your leadership team on privacy posture, risks, and recommendations.
04
Continuous Improvement
As your business evolves - new products, new markets, new vendors, new regulations - your vDPO adapts your privacy programme accordingly. Annual privacy programme reviews, regulatory change tracking, and proactive guidance on emerging obligations.
Strategic Intelligence
Inquiry & Methodology
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Under GDPR Article 37, you must appoint a DPO if you are a public authority, if your core activities involve large-scale systematic monitoring of individuals, or if you process special category data at scale. Even if you don't strictly require one, many enterprise customers and partners expect a named DPO as a condition of doing business. Either way, having one is good practice.
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ROPA maintenance, DPIA reviews for new products and features, DSAR intake and coordination, breach assessment and notification management, processor due diligence and DPA reviews, regulator correspondence, privacy training for your team, and regular reporting to leadership on privacy posture and emerging risks. The scope adapts to your business.
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If your company is established outside the EEA but offers goods or services to, or monitors the behaviour of, individuals in the EU, you must designate an EU-based representative under Article 27. This person is the contact point for supervisory authorities and data subjects. We provide this service bundled with vDPO or as a standalone appointment.
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A consultant gives you advice and leaves. A vDPO is a formally appointed role with legal accountability under GDPR. Your vDPO is registered with the supervisory authority, accessible to data subjects, and operates with the independence Article 38 requires. They are embedded in your organisation as an ongoing function, not a project.
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Absolutely. Most of our vDPO clients have internal legal counsel or a compliance lead. Your vDPO integrates with that team - providing specialist privacy expertise, handling the operational workload, and ensuring the DPO function maintains the independence the regulation requires. We complement your existing capability rather than replacing it.
Ready for privacy leadership without the full-time hire?
Precision in Compliance.
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