DPO vs Article 27 Representative — What Is the Difference?

A Data Protection Officer and an Article 27 representative are not the same thing. 

The distinction matters.

A DPO supports internal data protection compliance. An Article 27 representative acts as a local contact point where a company is outside the UK or EU but is still caught by the UK GDPR or EU GDPR.

Many companies entering the UK or EU market need an Article 27 representative, but do not need a DPO. We focus on that specific requirement: straightforward UK and EU GDPR representation without unnecessary compliance add-ons.

A DPO is required only in certain circumstances. Under the UK GDPR, the ICO says an organisation must appoint a DPO if it is a public authority, carries out large-scale regular and systematic monitoring as a core activity, or carries out large-scale processing of special category or criminal offence data as a core activity.

An Article 27 representative is different. It is about market presence.

You may need a representative if your company is not established in the UK or EU, but you offer goods or services to people there or monitor their behaviour there. The representative acts as a point of contact for individuals and regulators.

In simple terms:

A DPO looks inward. They advise your organisation on data protection compliance.

An Article 27 representative looks outward. They give individuals and regulators a local contact point.

You might need a representative without needing a DPO. For example, a US software company selling into the UK may need a UK GDPR representative, even if its processing does not trigger the DPO requirement.

You might need both if your processing is higher risk. For example, a healthtech platform targeting UK and EU users and processing health data at scale may need a DPO as well as UK and/or EU representatives.

But the roles should not be confused:

• A representative is not a DPO.
• A DPO is not a substitute for a representative.

The takeaway:
If you are expanding into the UK or EU, do not assume you need a full DPO service. You may simply need a local Article 27 representative.

Need UK or EU Article 27 representation?
We provide focused representative services for companies entering the UK and EU markets — without bundling in DPO services you may not need.