Does your charity need a Data Protection Officer?

As part of Give as you Live's ongoing commitment to supporting charities with expert-led resources and services, we're excited to introduce Hope & May, a leading legal practice specialising in Data Protection Law that supports charities with outsourced DPO services, compliance audits, breach response, and more.

Read on for their expert advice on whether your charity is legally required to appoint a Data Protection Officer (DPO)!

What Hope & May want charities to know:

Understanding your legal requirements

Hope & May work with charities and not-for-profits that are deeply committed to making a difference, but often uncertain about their legal responsibilities under UK GDPR. One key question they help many organisations answer is:

Does your charity need a DPO?

According to official guidance from the Information Commissioner’s Office (ICO), if your organisation engages in certain types of data processing activities, you are required to appoint a DPO. This isn't just a recommendation - it's a legal requirement.

When must charities appoint a DPO?

The ICO states that organisations must appoint a DPO if any of the following apply:

Your core activities involve large-scale processing of special category data
Your core activities require regular and systematic monitoring of individuals on a large scale.

Charities may often fall into one or both of the above categories.

Examples that require a DPO appointment:

You would be required to appoint a DPO if your organisation carries out activities such as:

Tracking behaviour on your website or through digital fundraising tools
Operating CCTV or surveillance systems at scale
Maintaining large databases of service users, volunteers, or donors
Collecting and storing special category data (such as health, ethnicity, or religious beliefs)
Running long-term support, casework, or programme monitoring involving personal data
Processing personal data across multiple locations or at high volume

If you answered “yes” to any of these, the ICO response is as follows: “Your organisation will need to appoint a data protection officer.” Based on the answers given, you probably need to appoint a data protection officer (DPO).

The full guidance is available on the ICO’s website, but for most charities, the message is simple: a DPO may not be optional, and should be appointed for good governance in the organisation.

Why it matters

Having a qualified DPO in place helps your organisation:

Stay legally compliant and avoid regulatory fines
Protect sensitive data relating to supporters, beneficiaries, and staff
Manage risks with confidence
Respond effectively to Subject Access Requests and potential data breaches
Demonstrate accountability and good governance to funders, partners, and the public

Hope & May: DPO Services for Charities

Hope & May specialise in outsourced DPO services for charities, foundations, and community organisations across the UK. Their tailored support means you get:

✅A named expert acting as your official DPO
✅Ongoing guidance and hands-on support
✅Policy reviews, risk assessments, and compliance checks
✅Staff training and process improvement
✅Peace of mind knowing you’re fulfilling your legal obligations

Need help determining your status?

If you're unsure whether your organisation’s activities meet the threshold, or you're ready to appoint a DPO but don't know where to start, Hope & May are here to support you.

Contact the team at Hope & May today for expert guidance at info@hopeandmay.com.

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