GDPR mandate · Data Protection Officer

DPO in Luxembourg.

Looking for a DPO in Luxembourg? Luxgap appoints a certified data protection officer, registered with the CNPD, to manage your GDPR compliance day to day. We work across the whole of Luxembourg and in the neighbouring border regions (Belgium, France, Germany).

Who must appoint a DPO in Luxembourg?

The GDPR (Article 37) requires a DPO to be designated in 3 cases: public authorities, large-scale processing (video surveillance, biometrics, profiling), and processing of sensitive data. The Luxembourg CNPD also recommends a DPO above 50 staff, or for any activity providing services to individuals (health, education, social services).

In practice: banks, insurers, investment funds, fiduciaries, hospitals, municipalities, schools, outsourced HR, e-commerce. But also industrial SMEs, restaurants, law firms and associations that keep files on individuals.

Why outsource rather than hire in-house?

Hiring a senior DPO in Luxembourg is slow and expensive, and the market is tight. An outsourced Luxgap DPO is a complete team (lawyers + cyber engineers + developers), operational immediately, for a fraction of the cost of an internal hire. For most Luxembourg SMEs and mid-sized companies, the numbers speak for themselves.

The other advantage: independence. The DPO must be hierarchically independent (Article 38 GDPR). An internal DPO reporting to the CIO or the HR director creates a structural conflict of interest. An external DPO meets that requirement by design.

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What does a Luxgap DPO actually do?

Our mandate covers the 9 GDPR workstreams: records of processing activities (Article 30), data protection impact assessments (DPIAs) (Article 35), data subject rights (access, rectification, erasure, portability), breach notifications to the CNPD within 72h (Article 33), processor contracts (DPA, Article 28), safeguards for transfers outside the EU (standard contractual clauses), internal training, relations with the CNPD (responses to inspections, complaints), personal data policy and information notices.

You appoint us officially, we carry the operational responsibility. You stay focused on your business.

How is a Luxgap DPO mandate structured?

Three tiers, depending on your size and exposure:

Essential (SMEs, 10-50 staff): 1 day/month on site, records kept up to date, DPIAs on request, annual committee.
Standard (50-250 staff): 2 days/month, annual audit, on-call incident handling.
Premium (250+ or sensitive sector): dedicated team, integration into executive committees, increased on-site presence.

Every tier includes the official registration with the CNPD, professional liability insurance, and a certified DPO (CIPP/E or equivalent) taking charge. Quote-based pricing, calibrated to your actual scope.

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