Why should I appoint a GDPR Representative?
- John McVeigh
- Jan 22
- 4 min read
Updated: May 22
As data protection laws grow more complex and enforcement more assertive, businesses based outside the EU or UK—but processing personal data of their citizens—are required to comply with the General Data Protection Regulation (GDPR). One of the most overlooked but essential obligations for such businesses is the appointment of a GDPR Representative under Article 27.
This article explains what a GDPR Representative is, why it matters, the risks of non-compliance, and how ASSUREMORE can help you stay compliant with minimal disruption to your business.
What Is a GDPR Representative?
A GDPR Representative is a person or organisation located within the European Union and/or United Kingdom that acts as a point of contact between your business and local supervisory authorities or data subjects (individuals whose personal data you process).
This is a legal requirement for most organisations outside the EU or UK that:
Offer goods or services to individuals in these regions; or
Monitor the behaviour of individuals in these regions (e.g., through analytics, profiling, or advertising technologies).
Understanding Article 27 of the GDPR
Article 27 of the GDPR mandates that any data controller or processor not established in the EU or UK—yet offering goods or services to individuals there or monitoring their behaviour—must appoint a local representative.
This representative must:
Be based within the EU and/or UK (depending on your markets);
Be authorised in writing to act on your behalf regarding data protection matters;
Serve as a contact point for supervisory authorities and data subjects;
Maintain documentation of your processing activities as required by Article 30.
Why Appointing a GDPR Representative Matters
1. Compliance with the Law
Failing to appoint a GDPR Representative when required is a direct breach of Article 27. Regulatory authorities have taken action, and the lack of a representative can be an aggravating factor in determining penalties.
2. Avoiding Fines
Non-compliance with Article 27 can lead to significant financial penalties. GDPR fines can reach up to €10 million or 2% of your annual global turnover—whichever is higher.
3. Enabling Trust and Transparency
Having a designated representative makes your organisation more trustworthy to both data subjects and regulators. It signals your commitment to privacy and to handling personal data responsibly.
4. Streamlined Communication
Your GDPR Representative acts as your local contact. This ensures timely responses to regulatory enquiries, data subject access requests, and breach notifications—protecting your business from reputational damage and legal exposure.
Who Needs a GDPR Representative?
You need a GDPR Representative if:
Your organisation is based outside the EU or UK;
You process personal data of individuals in the EU or UK;
The processing relates to offering goods or services, or monitoring behaviour (e.g., through cookies, analytics tools, or user tracking).
There are limited exemptions, typically for:
Occasional processing;
Low-risk processing;
No processing of special category data.
Even if you believe you qualify for an exemption, a risk-based assessment is strongly recommended.
Why Choose ASSUREMORE as Your GDPR Representative?
At ASSUREMORE, we offer reliable and professional GDPR Representation tailored to non-EU/UK businesses of all sizes. Here's why companies choose us:
UK & EU Representation: We can act as your GDPR Representative for both UK and EU requirements, giving you comprehensive coverage.
Rapid Response: We handle all communications from regulators and data subjects promptly and professionally.
Record-Keeping: We maintain the required documentation of your data processing activities.
Privacy-Focused: With deep expertise in data protection law and industry best practices, we ensure your compliance posture is secure and credible.
Transparent Pricing: Fixed annual fees with no hidden charges.
We tailor our services to your sector, scale, and regulatory risks—giving you peace of mind and demonstrable compliance.
Frequently Asked Questions (FAQ)
What are the risks of not appointing a GDPR Representative?
Failing to appoint a representative can result in enforcement action, reputational harm, and GDPR fines. It may also limit your ability to operate in EU/UK markets.
Has enforcement already occurred?
Yes. Supervisory authorities have already issued warnings and fines to companies for failing to comply with Article 27. For example, the Dutch Data Protection Authority fined Locatefamily.com €525,000 for failing to appoint an EU representative, and Clearview AI
was fined €600,000 in Italy for GDPR violations including the failure to designate an EU representative. Fines for breaches of Article 27 can reach up to €10 million or 2% of global annual turnover—whichever is greater.
Does ASSUREMORE provide services for both the EU and UK?
Yes. We offer dual representation to cover EU and UK GDPR obligations—perfect for businesses targeting customers in both markets.
Do I need a GDPR Representative if I already have a DPO?
Yes, these are different roles. A Data Protection Officer (DPO) advises on compliance internally, while a GDPR Representative serves as your legal presence in the EU or UK and handles external communication with authorities and data subjects.
Trusted by Clients Around the World
At ASSUREMORE, we take pride in building lasting relationships with our clients. We invite you to read what our customers say on our client testimonials page. Their success stories reflect our commitment to excellence and practical, actionable compliance support.
Take the Next Step
If your business is targeting the UK or EU markets and you're unsure whether Article 27 applies to you, reach out to us for a free, no-obligation consultation.
Contact ASSUREMORE Today
Representing you in the UK and EU – Trust ASSUREMORE to be your GDPR bridge.
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