Under the General Data Protection Regulation (GDPR), companies are required to appoint a data protection officer if certain legal conditions are met. The obligation does not depend solely on the size of the company, but primarily on the type, scope, and purpose of the data processing activities.

A data protection officer is required, for example, if the company’s core activities involve the regular and systematic monitoring of individuals on a large scale, such as tracking user behavior, analyzing customer data, or processing extensive personal profiles.

The appointment is also mandatory if a company processes large amounts of special categories of personal data, including health data, biometric data, genetic data, or information about religious beliefs, political opinions, or other particularly sensitive information.

In Germany, a data protection officer may also be required under additional national regulations. According to the German Federal Data Protection Act (BDSG), companies generally need to appoint a data protection officer if 20 or more employees regularly process personal data as part of their work.

Even when there is no legal obligation, appointing an external data protection officer can be beneficial. Especially for small and medium-sized enterprises, an external expert provides independent advice, ensures GDPR compliance, supports documentation requirements, and helps reduce legal and operational risks.

An external data protection officer from Tulos supports companies with the implementation of GDPR requirements, the review of processes, employee training, data protection audits, and ongoing compliance management. This allows companies to meet their legal obligations while focusing on their core business.