Outsourced DPO: When Does It Make More Sense Than Hiring Internally?

The LGPD requires companies that process personal data at scale — or that handle sensitive data such as health information — to have a Data Protection Officer, known in Brazil as the encarregado de proteção de dados.

The question that immediately follows, for most managers, is whether to hire internally or outsource. The answer depends on the company's size, stage and structure. And for the vast majority of Brazilian small and mid-sized businesses the answer is clear: an outsourced DPO is more efficient, cheaper and safer.

What is a DPO and what do they do?

The DPO is the person responsible for ensuring the company processes personal data in line with the LGPD. Their duties include:

• Guiding staff and managers on LGPD obligations
• Acting as the official channel of communication with the ANPD
• Receiving and answering data subject requests (clients, patients, employees)
• Following up on audits and inspections
• Ensuring internal policies and processes remain compliant
• Reporting security incidents within the legal deadline

Internal DPO vs. outsourced DPO: the direct comparison

Cost — A senior in-house DPO with the qualifications the LGPD calls for costs, on average, between BRL 8,000 and BRL 18,000 a month in salary alone, before payroll charges, benefits and infrastructure. An outsourced DPO delivers the same level of expertise for a fraction of that, on monthly contracts that fit any SMB budget.

Expertise — An internal DPO specializes in your company's reality. An outsourced DPO brings accumulated experience from dozens of cases, sectors and situations — which means faster answers, better practices and a market view that stays current.

Availability — An internal DPO gets sick, takes holidays, resigns. An outsourced DPO is a continuous service: compliance is not interrupted by personal events, and there is always a backup team available.

Regulatory updates — The LGPD evolves. The ANPD publishes resolutions, guidance and precedents regularly. An outsourced DPO firm tracks those changes in real time and updates its clients' processes accordingly. An internal professional would have to dedicate exclusive time to that.

For 80% of Brazilian SMBs, an outsourced DPO delivers more result at less cost — without the risk of being left unprotected by a resignation or a leave of absence.

When does an internal DPO make more sense?

There are situations where hiring internally is the better strategy:

• Large corporations with massive data volumes and complex operations across multiple countries
• Companies in finance, healthcare or technology with highly specific data structures and their own sector regulation
• Organizations with more than 500 employees and robust legal and IT departments that justify in-house specialization

For every other case — and that includes the vast majority of clinics, private practices, SMBs, distributors and service providers — the outsourced DPO is the smarter choice.

What to look for when choosing an outsourced DPO

• Legal qualification: the service should be led or supervised by lawyers specialized in data protection
• Experience in your sector: a DPO who knows the particulars of healthcare, for instance, delivers far better results than a generalist
• Incident support: check whether the contract covers support in the event of a breach and the notification to the ANPD
• Integrated technology: platforms combining an outsourced DPO with compliance management software give you more control and visibility
• A clear contract with no surprises: check the scope, the SLAs and what is and is not included

DPO as a Service with SafetyFYI

• DPO formally appointed with the ANPD
• Data subject requests handled end to end
• Incident notification within the legal deadline
• Periodic compliance reports
• Continuous legal support