As your business grows, there comes a point where you need to formalise how data protection is handled, including who takes on the data protection officer (DPO) role.
If you’re currently trying to figure out whether your company needs an in-house DPO or an outsourced DPO, you’re not alone. Most scaleups reach this crossroads sooner or later, usually triggered by due diligence, an enterprise deal, entering a regulated market, or simply the realisation that data protection has become too complex to manage ad hoc.
The difficult part? Even after research, it’s still tough to know which option actually fits your organisation. Choosing between an outsourced DPO vs in-house DPO isn’t a simple “one is better” decision. The real question is: “Which model solves the problems our business actually has?”
This guide breaks down how each model works, the common pitfalls companies run into, and how many scaleups are now combining the strengths of both.
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Under GDPR Articles 37–39, a DPO carries formal regulatory responsibilities. They oversee how personal data is handled, advise on compliance, monitor high-risk processing, and act as the contact point for the ICO. Crucially, the DPO must remain independent, with a direct reporting line to senior leadership.
That’s the legal definition, but in a scaling business, the practical reality is far broader.
As you grow, your data landscape becomes more complex almost overnight. A DPO isn’t just reviewing policies or signing off DPIAs; they’re keeping pace with rapid product changes, new workflows, datasets, and risks, each of which can all affect compliance.
Hiring an in-house DPO can feel like the most straightforward option for many scaleups. Someone inside the business, close to the detail, available when you need them. And there are real advantages to that, but they also come with some pretty significant trade-offs.
An internal DPO sees the day-to-day reality, not just what’s written in a policy. They understand how data moves through your product and systems, how teams operate, and where the real risks tend to sit.
They’re on Slack, in meetings, and present for the ad-hoc decisions that don’t always make it into a formal request.
They can champion privacy internally, shaping mindset and behaviour across the business.
Some leadership teams value having someone internally who can represent data protection in conversations with senior leadership.
A full-time DPO is a significant investment once you add benefits, employment overhead, and the privacy tooling they’ll still need.
If they’re off sick, on holiday, or move on, you lose immediate cover - meaning urgent issues go unanswered and other tasks can fall through the cracks.
Experienced privacy professionals are in high demand. Turnover is common, and replacement processes can be slow and disruptive.
It’s rare for one person to be equally strong across AI, DPIAs, international transfers, sector-specific requirements, vendor risk, and operational processes.
Internal politics, competing priorities, and decision bottlenecks can make it harder for a lone DPO to push change at the pace the business needs.
Even with an excellent internal DPO, documentation, registers, evidence tracking, and data discovery can’t be run manually. Without a privacy management system, things quickly become inconsistent or out of date.
For companies who don’t want (or need) a full-time internal hire, an outsourced DPO can be a flexible and cost-effective option. You get expertise on tap, without the overhead of bringing someone in-house. And when it’s done well, there are real benefits - especially for scaleups dealing with more complex data protection challenges.
But this model still comes with some trade-offs.
You avoid salary, benefits, and employment overhead, and you only pay for the level of support you actually need.
External DPOs have clearer independence, which is especially valuable in regulated sectors or where impartiality is essential.
Instead of depending on a single internal hire, outsourced teams can bring in the right expertise for the right task and industry.
They’re not tied up in internal dynamics, so their guidance tends to be more balanced, pragmatic, and impartial.
When the business hits busy periods - audits, new products, vendor reviews, market expansion - external teams can scale up support without gaps in coverage.
Most outsourced DPOs bring well-tested processes and templates that would take an internal hire months to build.
Many traditional outsourced DPO services only spring into action when an issue emerges. Instead of actively monitoring compliance risk, they become reactive, spotting problems late rather than helping prevent them.
Companies frequently report that their assigned DPO has changed or left entirely. This often means onboarding a new DPO who lacks familiarity with the business, sector, or historic decision-making - leading to gaps, rework, and delays.
We run proactive risk committees, keeping senior leadership informed about emerging and top data protection risks specific to their business.
Our platform includes automated data discovery, enabling us to continuously identify new high-risk processing activities and systems as they arise, before they become issues.
We pay best-in-class rates, which aren't as easy to pay when hiring in-house, and maintain a strong focus on culture, ensuring we attract and retain top DPO talent.
Our DPOs work within a collaborative team, rather than operating in isolation like typical in-house DPOs, creating a more enjoyable and engaged employee experience which drives retention up.
Plus the Trust Keith platform collects and tracks all key contextual information about each customer, so if a DPO takes annual leave or transitions, continuity is preserved and the incoming DPO has full context from day one.
Because both models offer strengths and weaknesses, many scaleups find the decision more difficult than expected. In-house brings context and proximity; outsourced brings expertise and breadth.
But neither model alone covers everything a scaling company needs.
That’s why more and more companies are choosing a hybrid approach. In practice, it gives them the best of both options, without being limited by either one.
A hybrid approach lets you keep an internal owner who understands the day-to-day, while adding external expertise for the complex or high-risk work. It removes the risk of relying on a single individual - you get support through holidays, sick leave, and busy periods.
Teams still have someone close to the business, but they’re also backed by specialists who bring fresh perspective and broader experience. The result is fewer blind spots, better decisions, and often a more cost-effective setup than building everything in-house.
This is the direction many scale-ups are moving in, and it’s the approach Trust Keith was built around: combining an embedded expert with the structure, judgement, and continuity that businesses need to keep privacy running properly.
With Trust Keith, you get the best of the in-house and outsourced DPO models:
It means you don’t have to compromise between context or expertise - you get both, working together, through one integrated approach.
Plus, alongside your embedded expert, Trust Keith includes an intelligent privacy management platform for all the operational work — data mapping, assessments, registers, evidence, and monitoring.
With most approaches, software is an extra cost. With Trust Keith, it’s included, so you’re not buying separate tools or managing privacy through scattered systems.
Both in-house and outsourced DPO models have real strengths and real limitations. For many UK scaleups asking “Do I need a DPO?”, the hybrid model offers the strongest balance of context, continuity, and specialist capability.
The right choice for your business will come down to your risk profile, complexity, budget, and how fast things are changing. But whatever model you choose, the essentials stay the same: continuity, capability, and the ability to prove compliance at any moment.
If you want a solution that brings those strengths together, the Trust Keith approach may be a good fit. Chat to our team today, and we’ll show you how the Trust Keith model can support your scaleup.