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Infraspine provides a named, qualified Data Protection Officer as an outsourced service — giving your organisation full GDPR compliance coverage, DPIA reviews, subject access request handling, and breach notification support at a fraction of the cost of a full-time hire.
Our DPO as a Service covers the full scope of data protection obligations — from the statutory DPO function and GDPR programme through to breach response and staff training.
Infraspine provides a named, qualified Data Protection Officer to fulfil your obligations under Article 37 of the GDPR. Our DPO acts as the primary point of contact for your supervisory authority and data subjects, maintains independence from management as required by the regulation, and has no conflict of interest with other duties. The DPO function includes regular engagement with your senior leadership team and IT department, attendance at relevant governance meetings, and an annual data protection review. We maintain a DPO register entry with the relevant supervisory authority on your behalf and ensure that all organisational activities involving personal data processing are reviewed for compliance before implementation, preventing compliance issues from arising rather than reacting to them after the fact.
A functioning DPO must be underpinned by a structured GDPR compliance programme — not just a privacy policy on a website. Infraspine builds and maintains a comprehensive compliance programme including an Article 30 Record of Processing Activities (ROPA), data retention schedules, data mapping documentation, privacy notices for all processing activities, consent management frameworks, lawful basis assessments, and data sharing agreements with third parties. We conduct an annual compliance review to assess the programme against changes in regulatory guidance, enforcement decisions, and your organisation's own processing activities. The compliance programme is documented in a compliance management register that provides evidence of your accountability obligations under GDPR Article 5(2).
A Data Protection Impact Assessment (DPIA) is mandatory under GDPR Article 35 for any processing that is likely to result in a high risk to individuals — including large-scale processing of special category data, systematic monitoring, and automated decision-making. Many organisations conduct DPIAs as a tick-box exercise without genuinely identifying and mitigating risks. Infraspine conducts rigorous DPIAs using the ICO's recommended methodology: describing the processing, assessing necessity and proportionality, identifying and assessing risks, and identifying measures to mitigate those risks. Each DPIA concludes with a risk treatment plan that documents residual risks and management sign-off. We also provide a DPIA screening tool to help your teams identify when a DPIA is required before a new project or system goes live, avoiding the compliance gap that occurs when DPIAs are completed after implementation.
Data subjects have the right to request access to their personal data under GDPR Article 15, and organisations must respond within one month. Subject Access Requests (SARs) can be complex and time-consuming — particularly when data is spread across multiple systems, cloud services, and third-party processors. Infraspine manages the end-to-end SAR handling process: receiving and logging requests, verifying the identity of the requestor, coordinating data searches across your systems, reviewing responses for third-party personal data that should be redacted, and preparing the final response within the statutory deadline. We also handle requests for erasure (the right to be forgotten), restriction of processing, rectification, and data portability. Our SAR management process includes a full audit trail for every request, providing evidence of compliance in the event of a regulatory investigation.
GDPR requires organisations to notify the relevant supervisory authority of a personal data breach within 72 hours of becoming aware of it — a timeline that many organisations fail to meet because they do not have a documented breach response process. High-risk breaches must also be notified to the affected data subjects without undue delay. Infraspine provides a complete breach notification management service: a documented incident response procedure for data breaches, a 24-hour breach triage hotline, assessment of whether a breach meets the notification threshold, preparation and submission of supervisory authority notifications, communication with affected data subjects, and post-incident review to prevent recurrence. We maintain a breach register for your organisation in line with GDPR Article 33(5), which is a mandatory accountability document that supervisory authorities can request at any time.
Human error is the most common cause of personal data breaches — sending data to the wrong person, failing to use BCC, sharing login credentials, or falling for phishing attacks that expose personal data. GDPR requires organisations to ensure that staff who process personal data are aware of their obligations and receive appropriate training. Infraspine delivers a staff training and awareness programme that includes annual mandatory GDPR awareness training for all staff, role-specific training for staff who handle sensitive personal data, a data protection policy induction for new starters, and periodic awareness communications covering data protection topics. Training completion is tracked and reported, providing evidence of your accountability obligations. We also provide a data protection handbook for staff that explains their key obligations in plain language without legalese.
Common questions from organisations considering outsourced data protection officer support.
Contact Infraspine to discuss our DPO as a Service programme. We will explain what is included, how the named DPO function works, and how quickly we can get your organisation into compliance.