DPO as a Service For Tech Startups

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DPO for Founders of Tech Startups

Data Privacy Services provides skilled and experienced data protection professionals (DPO) for all types of tech startups.  We provide the advice and guidance needed for founders to be compliant and also pass the necessary due-diligence for obtaining investment.

Note – we specifically specialise in Artificial Intelligence (AI) and how this must be implemented taking into account data protection legislation.

Role of a DPO

A DPO ensures that you meet a specified legal requirement and acts as the point of contact for all data protection requirements.

Reviews and Monitors Compliance

A DPO’s role includes the review and on-going monitoring of compliance with the data protection legislation.

This typically means that the DPO will complete an annual audit of the organisations compliance and develop and maintain a Privacy by Design Plan.

Manages Privacy by Design

As part of the compliance monitoring activities the DPO will review how Privacy by Design is implemented into the businesses operational processes and procedures.

This is a specific requirement under Article 25 and must be in place to be compliant.

Manages Data Breaches

The DPO should act as the central point of contact for any data breach that occurs within the organisation (assuming this involves personal data).

The DPO should have the experience needed to follow the legal and best practice methodology for managing incidents. They will provide advice and guidance and ensure that the correct steps are taken to minimise risk.

Note – they will also be the point of contact with the associated Information Regulator (e.g. the UK’s Information Commissioners Office).

Record of the Processing

The DPO is required to keep an up-to-date record of the processing (ROPA) of the personal data that the business processes as a Data Controller and Data Processor.

The ROPA is a legal requirement under Article 30.

Management of DSARs

Data Subject Access Requests (DSARs) are commonly requested by individuals (i.e. the Data Subject) when exercising their rights under data protection legislation.

The DPO must ensure that the requests are appropriately managed in accordance with the legislative requirements.

Provides Training

A DPO should provide training to all staff and contractors on matters of both data protection and information security awareness.

There are specific legal requirements to train staff (under both Articles 5 and 32) so the DPO must ensure that this is in place and is fit for purpose.

UK and EU Representation

Article 27 of the EU and UK GDPR requires that organisations provide a geographically located representative for citizens of the EU and UK.

UK Representative

This applies when an organisation is based in one region (i.e.the EU) and they process UK citizens data.

In this case, the UK representative must have an office in the UK.

EU Representative

This applies when an organisation is based UK and they process EU citizens data.

In this case, the EU representative must have an office in the EU.

So, in the case of a tech startup this applies if you have workers, contractors or partners that reside for at least part of the year inside the EU.

Note – We have offices in both the UK and EU and can support this requirement.

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Processing of personal data within a Tech Startup

There are some specific requirements to consider when processing personal data within this type of business.

Investment Due-Diligence

We provide support to founders when needing to establish the necessary level of compliance required to pass data protection and information security due-diligence when seeking investment.

Founders often find this a barrier to obtaining sufficient interest from both Angel Investors and Venture Capitalists.

Note – exit plans for investors also have to include full data protection and information security compliance. 

Controller v Processor Relationships

Many startups have challenges in relation to their data processing arrangements and their classifications under the legislation.

We provide direct support for the development Data Processing Agreements and support the development of data protection and information security clauses within Master Service Agreements.

Software Requirements

Businesses have many different software requirements, all of which need to conform with data protection.

Systems such as:

  • CRM solutions
  • HR solutions
  • Finance solutions
  • Sales and Marketing solutions
  • Operational software solutions
  • Web applications

The use of the above software will need to have the appropriate risk assessments and compliance measures in place.

Management of Sensitive Personal Data

Many Tech Startups have to process sensitive (special categories) data about their end-users.

Note – this means that some businesses have a legal requirement to appoint a DPO.

Typically, this is done under the basic requirements of providing the service but the correct legal basis for processing and other requirements need to be followed. 

Data Privacy Services are experienced in managing complex software data protection challenges where there is significant sensitive information that is processed during the use of the software.

Also, Data Privacy Impact Assessments (DPIA) are required under the legislation for all of this category of processing.

Article 8 - Children's Data Processing

In terms of data protection, children under the age of 13 have to be treated differently than those aged 13 and over.

This causes significant complexity for some Tech Startups and the way that the legal basis for the processing is obtained must be in compliance with the legislation.

There are crucial rules to follow with regards to how businesses communicate and manage the legal the basis for processing in areas such as:

  • Newsletters /  SMS
  • Media usage (e.g. images, CCTV etc)
  • Social media
  • Marketing communications
  • General photography in and around the establishment
Complex Data Subject Requirements

Businesses process personal data of a wide variety of individuals also known data subjects.

These include:

  • End-users
  • Customers
  • Suppliers
  • Prospects
  • Employees
  • Children under the age of 13
Policies and Procedures

There are numerous policies and procedures that must be in place in order for the organisation to be compliant.

Also, these documents must be broadly communicated, understood and implemented to demonstrate compliance.

Information and Cyber Security

All Tech Startups must be doing everything they possibly can to secure the integrity, confidentiality and availability of personal data.

This requirement is complex and must be fully assessed as to what is required for compliance.

Note – this also includes due-diligence on your supplier network.

We are experts in guiding Tech Startups on the best approach to comply with this area of compliance.

Artificial Intelligence (AI)

Many Tech Startups are now incorporating AI into their software solutions and also into their own business operations.

The rules around AI adoption and data protection are increasing and becoming more complex.  We can guide you through the requirements and complete the necessary compliance deliverables.

IT User

Are you concerned about your information security?

Current Incentives

We are offering discounts of 10% for 6 month contracts paid up front of 15% for 12 month contracts paid up front

DPO Service Levels

Standard

£75/month
  • Dedicated DPO
  • Registration of DPO with the ICO
  • Free Data Protection Policy
  • Access to Customer Portal
  • Access To Data Breach Support
  • Access To DSAR Management
  • Standard Dark Web Monitoring
  • Reduced Hourly Rates

No fixed term contract, discounts are available off the stated prices

Benefits of engaging an outsourced DPO

We are an affordable and cost-effective option

There are many reasons to outsource the DPO function within your business, e.g.

Avoiding a conflict of interest – there are legal requirements regarding the DPO and the potential for conflict of interest.  That said, typically a founder, business owner, manager or functional head cannot perform the function of a DPO.  So engaging a DPO from Data Privacy Services removes this as an issue.

It’s rarely a full-time role – the DPO role isn’t often required to be a full time role within most businesses.  Outsourcing to us enables you to engage a part-time DPO on a flexible working arrangement.

The DPO has to be qualified and experienced – this is a challenging requirement for most organisations to fulfill.  Employing an experienced certified DPO will put a significant additional cost to your operating overheads.  Engaging one of our DPO resources is far more affordable and cost-effective.

You can call on additional resources – Data Privacy Services has a number of DPOs and also additional professional consultants who specialise in other areas such as information and cyber security.

We also provide you with additional services – these include training courses, online portal and Dark Web monitoring services.  You will also be able to access some of our information and cyber security solutions to ensure that you can protect your personal data.

Our Certifications

Certifications

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