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Penby

Fractional DPO

Your organisation holds personal data on behalf of people who trust you to protect it. That responsibility demands dedicated expertise.

Under UK GDPR, the obligations on an organisation processing personal data are the same whether you have ten employees or ten thousand. A full-time DPO may be a disproportionate expense – but data protection handled internally, by someone without specialist knowledge, leaves your organisation exposed. A fractional DPO gives you dedicated, qualified governance at a scale that fits.

Responsibilities

What a fractional DPO does

Regulatory liaison with the Information Commissioner's Office – acting as your named DPO contact for all ICO communications.

Data Protection Impact Assessments for new systems, processes, and high-risk processing activities.

Maintaining your Record of Processing Activities and ensuring lawful bases are documented and defensible.

Breach management – from initial detection through ICO notification within 72 hours to remediation and lessons learned.

Staff awareness training tailored to your organisation's actual data processing activities, not generic compliance theatre.

Proactive governance advice – building data protection into new projects, systems, and partnerships from the start, not as an afterthought.

Process

How the engagement works

Initial Assessment

We start with a thorough review of your current data processing activities, existing policies, and compliance position. This gives us a clear baseline – what's working, what's missing, and what needs attention first.

Standing Governance

A fixed number of days per month, agreed upfront. We integrate into your regular management cycle – attending governance meetings, reviewing new processing activities, handling subject access requests, and ensuring your documentation remains current and defensible.

Incident Response

Direct access to specialist support when something goes wrong. Data breaches, ICO enquiries, subject access requests with tight deadlines – we handle the response so you can focus on your business.

Eligibility

Who this is for

Your organisation processes enough personal data that governance can't remain someone's side responsibility – but a full-time DPO may not be proportionate. You might be a public sector body or local authority legally required to appoint a DPO. An SME with 10–250 employees where data protection keeps landing on the wrong desk. A growing business taking on significant data processing for the first time. Or a third-sector organisation handling sensitive categories and uncertain where the risks sit.

Related Reading

Let's simplify your data protection

Professional, practical advice without the fuss. Get in touch for a no-obligation chat about your specific needs.

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