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GDPR Local Representative Compliance EU and UK
Based on feedback from World of DaaS members, we wanted to put together this short guide on how to manage GDPR requirements related to having a local representative in the EU & UK. We created this overview on options to consider, but always recommend you check with your own legal counsel for the most up-to-date best practices.
Overview of GDPR Requirement
Both the EU GDPR (Article 27) and the UK GDPR (post-Brexit law overseen by the UK ICO) require that companies without a local establishment but which process personal data of residents must appoint a local representative:
EU GDPR: Requires a representative located in one of the EU Member States where affected individuals are based.
UK GDPR: Requires a representative with a physical address in the UK.
The representative must:
Act as the point of contact for supervisory authorities (EU DPAs or the UK ICO).
Be available to receive and forward inquiries from individuals exercising their data rights.
Keep records of processing activities on behalf of the company (in some cases).
Importantly, the EU and UK regimes are separate. Companies that target both EU and UK residents will generally need two different representatives — one in the EU and one in the UK.
What This Means for Companies
Administrative Obligation:
Appoint a local representative in both the EU and the UK if serving both regions.
Put contracts in place that clarify roles, responsibilities, and liability.
Operational Readiness:
Build workflows so that when a representative receives an inbound request, it is quickly routed internally.
Track and meet deadlines (typically one month) for responding to data subject requests.
Legal Exposure:
Supervisory authorities may hold the representative accountable for failing to facilitate communication.
Companies remain primarily responsible for GDPR/UK GDPR compliance, but the representative can face inquiries or enforcement contact.
Practical Considerations:
Decide whether to use a law firm, consultancy, or specialized GDPR rep service.
Ensure the representative has clear escalation channels into the company.
Document everything (requests received, responses provided).
Who Is Impacted
Non-EU Companies: Non-EU & Non-UK Companies: Any organization with no legal entity in the EU or UK but which:
Offers goods or services to individuals in either region; or
Monitors the behavior of individuals (e.g., tracking/analytics, profiling).
Examples:
A U.S.-based SaaS provider with customers in France and London.
A Canadian e-commerce store shipping to both the EU and UK.
An Australian ad-tech firm monitoring browsing behavior in both regions.
Dual Impact:
Serving both EU and UK customers = must appoint two separate representatives.
Having only one (e.g., in the EU) will not satisfy UK law, and vice versa.
Options to Approach
We surveyed World of DaaS Members to get their feedback on how they are managing this requirement. A few clear approaches have emerged:
Work with a Specialized Vendor
Several companies have partnered with dedicated GDPR/UK GDPR representative service providers.
These vendors typically offer compliance infrastructure, record-keeping, and formal representation.
Pricing often starts around $1,000 annually for SMBs, but can scale up significantly based on company size, data processing complexity, and the number of policies covered.
Contract an Individual Representative
Some members have opted to directly contract with an independent consultant (via platforms like Upwork).
This approach can be cost-effective for smaller companies with limited EU/UK exposure and limited volume of requests, which can help companies save money.
How To Contract an Individual Representative
When to Consider this Option?
Hiring an individual via Upwork, Freelancer, or a local contracting service can be a viable option for:
SMBs or startups with limited EU/UK exposure and lower inbound request volumes.
Companies looking to control costs before investing in a full-scale vendor solution.
Organizations that need basic compliance coverage quickly while building longer-term infrastructure.
Reminder: The representative must be physically located in the EU (for EU GDPR) or the UK (for UK GDPR). If your company serves both, you will need two separate individuals.
Posting a Job
Make sure to create a clear job posting for the individual. WoD Members can access our sample job post here
Agreement for Contractor
When coming to terms with the contractor, make sure you sign a clear agreement with the individual. We’ve created these sample EU GDPR Agreement and UK GDPR Agreement. As always, make sure you review and adjust depending on your own company’s legal and risk needs. In terms of compensation, often you can get contractors to agree to payments around $250 per year.
Updating Your Privacy Policy
Once you’ve secured a GDPR or UK GDPR representative, the next critical step is to update your Privacy Policy so that data subjects and regulators know how to contact them.
What to include:
Representative’s name or company name.
Physical address in the EU and/or UK (depending on which markets you serve).
Contact details (email and/or phone) for GDPR inquiries.
A clear statement that the representative acts as your local contact for GDPR/UK GDPR matters.
Example wording (for EU GDPR):
For individuals located in the European Union, we have appointed [Representative Name / Company] as our EU representative under Article 27 of the GDPR. You may contact them regarding GDPR matters at: [Address], [Email].
Example wording (for UK GDPR):
For individuals located in the United Kingdom, we have appointed [Representative Name / Company] as our UK representative under the UK GDPR. You may contact them regarding data protection matters at: [Address], [Email].
Best practices:
Ensure the policy is publicly available on your website.
Keep the information current — update if your representative changes.
If you serve both EU and UK markets, list both representatives separately so users know whom to contact.
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