Outsourced Data Protection Officer (DPO)
บริการ DPO Outsource (Data Protection Officer) · § Advisory
What to know before you act
Organisations that regularly process large volumes of personal data, or whose core activity involves sensitive data, may be required to appoint a DPO. Many mid-sized firms outsource the role instead of hiring. We advise, monitor compliance, handle data-subject requests and act as contact point with the PDPC — working alongside your team, not replacing management's accountability.
Timing and external dependencies: Work starts after signing and handover of basic information; the first month usually goes to mapping processing and building the RoPA.
Official fee: No government fee to appoint a DPO, but DPO details must be notified as the PDPC requires — check the latest PDPC notifications.
Timing is not a promise of an outcome or hearing date. Check the notice, limitation period and current authority rules for your matter.
What to send for the first review
Send every relevant page, a dated sequence of events, any hearing or filing deadline, and the outcome you need. This lets counsel identify urgent steps, missing evidence and a precise scope of work.
- DPO appointment letter
- Job description and contact channels
- Reporting line
Legal Basis
PDPA §§41–42 and PDPC DPO Notification 2022 — the DPO must be independent, report to top management, and act as the contact point with the PDPC.
📚 Official sources — check the current law and procedure before acting
- สำนักงานคณะกรรมการคุ้มครองข้อมูลส่วนบุคคล (สคส.)— PDPC Thailand
- สำนักงานคณะกรรมการกฤษฎีกา — ตัวบทกฎหมายฉบับทางการ— Office of the Council of State
Who Needs This
Organisations processing large-scale sensitive data (clinics, hospitals, financial institutions, HR outsourcers) or performing systematic monitoring (insurance, logistics).
Required Documents
- DPO appointment letter
- Job description and contact channels
- Reporting line
Common Pitfalls
- Naming the IT or HR head as DPO when they would audit their own work — a conflict of interest
- Having a DPO but no route for rights requests to reach them, so deadlines are missed
- Believing that hiring a DPO transfers legal liability to them
Typical Use-cases
- Private hospital without an in-house legal team
- MNC with a Group DPO needing a local liaison
- Pre-Series-B startup evidencing a DPO for VC due diligence
FAQ
- Do we need a DPO?
- It depends on the volume and nature of data processed and PDPC notifications; we assess your actual activities first.
- Does an outsourced DPO work on-site?
- Mostly remote with scheduled meetings, on-site for audits, training or incidents.
- Can group companies share one DPO?
- The law allows sharing in some structures if the DPO is easily reachable by each; we review the group first.
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The information on this page follows the official sources below. Always check the latest version before you file.
- Office of the Judiciary— Office of the Judiciary
- Ministry of Justice— Ministry of Justice
- Lawyers Council of Thailand — Notarial Services Attorneys— Lawyers Council of Thailand
- Office of the Council of State — Thai law database— Office of the Council of State
- Royal Thai Government Gazette— Royal Thai Government Gazette
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