External Data Protection Officer Services


PharMarketing provides external Data Protection Officer (DPO) services for pharmaceutical, biotech, medical device, CRO and clinical research organisations operating across the European Union. Our outsourced DPO support combines GDPR expertise with practical knowledge of life sciences, clinical trials and health-data governance.


We help organisations establish independent, proportionate and effective privacy oversight—without the overhead of appointing a full-time in-house DPO.


When Is a DPO Required?

Under Article 37 of the EU General Data Protection Regulation (GDPR), an organisation must appoint a DPO in particular when its core activities involve large-scale processing of special-category data, such as health data, or large-scale regular and systematic monitoring of individuals. Public authorities are also generally required to appoint one. A DPO may be either an employee or an external provider operating under a service contract.


For life sciences organisations, a DPO assessment may be particularly relevant where activities involve:

  • Clinical trials, observational studies or real-world evidence programmes
  • Health, genetic, biometric or other sensitive personal data
  • Digital health platforms, wearables, connected devices or AI-enabled tools
  • Patient-support programmes and pharmacovigilance activities
  • Large-scale research databases, registries or data-sharing initiatives
  • Employee, candidate or other workforce-data processing
  • International transfers of participant, patient or healthcare-professional data


A Data Protection Impact Assessment (DPIA) can help identify and mitigate high privacy risks in a specific processing activity. However, a DPIA and a DPO appointment are separate GDPR obligations: completing a DPIA does not automatically mean a DPO is required, and the need for a DPO should be assessed against the Article 37 criteria and applicable national requirements.


Outsourced DPO for Life Sciences

An external DPO gives your organisation access to independent, senior-level privacy support while maintaining flexibility as your business, studies and data-processing activities evolve.


PharMarketing’s external DPO services may include:

  • Advising management and teams on GDPR and data-protection obligations
  • Monitoring privacy compliance, governance and accountability measures
  • Supporting DPIAs for clinical research, digital health and high-risk processing
  • Reviewing privacy notices, consent materials, ICFs, study protocols and data flows
  • Reviewing data-processing agreements, vendor contracts and international transfer arrangements
  • Supporting vendor and subcontractor privacy due diligence
  • Advising on data-subject requests, privacy incidents and breach-response processes
  • Liaising with supervisory authorities where appropriate
  • Delivering privacy training for staff, research teams and operational partners


Flexible DPO Packages

Our DPO service packages are designed for small and mid-sized organisations that need reliable, ongoing privacy support without building a dedicated internal function.


Depending on your requirements, support can begin with a limited number of hours per month and scale according to your organisation’s processing activities, clinical-study portfolio, geographic footprint and risk profile.


We provide responsive access to an experienced privacy professional for strategic guidance, operational questions and ongoing compliance support.


Speak With a DPO Specialist

Whether you are assessing whether a DPO is required, planning a clinical trial, implementing a new technology platform or strengthening your GDPR governance, PharMarketing can provide tailored external DPO support.


Contact us to discuss your data-protection needs and request a tailored quote.