Example engagement — illustrative
An outsourced DPO for a charity handling sensitive beneficiary data
National charity (~60 staff and volunteers) · Outsourced DPO
The challenge
A charity supporting vulnerable beneficiaries handled sensitive personal data and needed dedicated data protection oversight, but could not justify a full-time DPO on its budget.
What we did
- Established the outsourced DPO role with a clear remit and a route to the trustees
- Reviewed processing of beneficiary, donor and volunteer data and updated the record of processing
- Set up a monitoring rhythm — policy reviews, training and a log of data protection queries
- Advised on data protection impact assessments for new services and digital tools
- Acted as the point of contact for subject access requests, breaches and any ICO liaison
The outcome
The charity gained ongoing, independent data protection oversight proportionate to its size and its duty to vulnerable people.
Background
Charities that support vulnerable people often process exactly the kind of sensitive data that demands strong governance — health, financial hardship, safeguarding — while running on budgets that cannot stretch to a full-time specialist. That gap is what an outsourced DPO is designed to fill. In this illustrative example, a national charity of around 60 staff and volunteers knew data protection needed a proper owner, but hiring one internally was neither affordable nor a full-time job’s worth of work.
What we did
We established the outsourced Data Protection Officer role with a defined remit and, importantly, a direct line to the trustees so the function had the independence UK GDPR envisages. The first substantive task was to understand the data: we reviewed how beneficiary, donor and volunteer information was collected and used, and brought the record of processing activities up to date so decisions rested on facts rather than guesswork.
The real value of an outsourced DPO, though, is the ongoing rhythm rather than a one-off review. We set up a schedule of policy reviews and staff training, and kept a running log of the data protection queries that arise in day-to-day charity work — a volunteer asking what they can share, a fundraiser wanting to use a new platform. When the charity planned new services or adopted digital tools, we advised on data protection impact assessments before commitments were made. And we acted as the standing point of contact for subject access requests, for any personal data breach — including the duty to report a notifiable breach to the ICO within 72 hours — and for liaison with the regulator if needed.
Result
The charity secured continuous, independent oversight sized to its budget and its responsibilities. Trustees had assurance that data protection was actively managed rather than left to chance, and staff had someone to ask before problems became incidents.
This is an illustrative example of the kind of work we do. Details are representative, not a specific named client.