Data Protection Officer · European Union

Shared DPO for Public Bodies

One DPO for several public authorities or bodies, taking account of their organisational structure and size, under Article 37(3) of the GDPR.

Legal framework

The essentials in four points

Legal basis

Article 37(3) of the GDPR allows a single DPO to be designated for several public authorities or bodies, taking account of their organisational structure and size.

Designation by each body

Each body formally designates the DPO, publishes the contact details and notifies them to the supervisory authority.

Effective performance

The shared DPO must have sufficient resources and time to perform all tasks for every body served.

National arrangements

National law adds detail: Portugal expressly allows one DPO for several public entities, and in Spain provincial councils may support smaller municipalities.

Who it is for

  • associations of municipalities and inter-municipal bodies: that wish to organise the service for their members;

  • regional and provincial authorities: that support smaller municipalities in their area;

  • municipalities and their entities: municipal companies, agencies and foundations;

  • groups of agencies: bodies within the same ministry or department.

How it works

  1. joint assessment: an inventory of each body's processing and of the risks they share;

  2. conflict-of-interest review: a prior check for each body served;

  3. designation by each body: a separate designation act, publication and notification;

  4. common model, local application: shared policies and templates, adapted to each body;

  5. reporting: an annual report for each body and a consolidated view for the coordinating entity.

Benefits

  • economies of scale: shared costs and fees proportionate to each body;

  • consistency: the same rules and templates across all bodies;

  • joint training: common sessions for elected officials and staff;

  • coordinated response: joint handling of breaches affecting shared systems or suppliers.

Plans

  • Shared base: the statutory DPO tasks for each body, common templates and annual reports;

  • Shared advanced: adds impact assessments, joint training and support with personal data breaches.

Fees are set in a tailored proposal, with a common component and a component per body.

National offers: Portugal · Spain · Brazil

Other offers: Public bodies · Private organisations · Corporate groups · European Union

General information as at October 2026; it does not constitute legal advice.

Frequently asked questions

The shared DPO

Can one DPO serve several municipalities?

Yes. Article 37(3) of the GDPR allows it, taking account of the organisational structure and size of the bodies, provided the DPO can perform the tasks effectively for each of them.

Does each body still need to notify the supervisory authority?

Yes. Each body is a separate controller, so each designates the DPO, publishes the contact details and notifies them to the supervisory authority.

Can a coordinating entity procure the service on behalf of its members?

It can, within its powers and the applicable procurement rules. The designation of the DPO remains an act of each body.