Governance

DPO as a Service in Jordan — Your Outsourced Data Protection Officer

A qualified, independent Data Protection Officer on a fractional or retained basis — the expertise, accountability, and regulator liaison your organisation needs under Jordan’s Personal Data Protection Law, without the cost of a full-time senior hire.

Do you legally need a DPO?

Under the Personal Data Protection Law No. 24 of 2023, appointing a Data Protection Officer is not optional guidance — Article 11/A makes it mandatory for the controller in any of six cases:

The controller's primary activity involves processing personal data.
The controller processes sensitive personal data.
The controller processes the personal data of individuals lacking legal capacity.
The controller processes data that includes financial information.
The controller transfers data to databases located outside the Kingdom.
Any other case determined by the Personal Data Protection Council.

For the financial sector these triggers are decisive. Because processing financial information (trigger 4) and transferring data to databases outside the Kingdom (trigger 5) apply to virtually every bank, insurer, fintech, and payment provider, a DPO is effectively mandatory for CBJ-regulated organisations — not merely advisable.

This is general information, not legal advice; verify the current triggers and any implementing instructions against the Official Gazette.

For the full legal background, learn what a DPO is and when Jordan requires one.

What our DPO service includes

Formal appointment as your organisation’s Data Protection Officer, with support for any accreditation or registration required with the Personal Data Protection Council and the Unit within the Ministry of Digital Economy and Entrepreneurship.

Gap assessments benchmarking your processing against the PDPL and applicable CBJ instructions, with a prioritised remediation roadmap.

Data Protection Impact Assessments (DPIAs) for high-risk processing before it goes live.

Development of privacy policies, notices, records of processing, and internal procedures written to be used, not shelved.

Breach-response coordination that meets Article 20’s timelines — notifying affected data subjects within 24 hours and the Unit within 72 hours of a serious breach.

Regulator liaison as your point of contact for the Council, the Unit, and CBJ supervisors, handling correspondence, registrations, and data subject requests.

Role-appropriate staff awareness training, because most breaches begin with everyday human error.

Ongoing compliance monitoring: reviewing new projects, tracking regulatory change, and reporting to your management and board.

Why outsource the DPO role

Independence: an external officer is structurally insulated from internal politics and cannot be overruled by the departments they supervise — exactly the independence regulators expect of a control function.
Cost: senior data protection expertise on a fractional basis, without the salary, benefits, and recruitment cost of a permanent executive hire.
Breadth: experience across banks, insurers, fintechs, healthcare, and government that a single in-house hire would take years to accumulate.
Continuity: your compliance programme does not collapse when one employee resigns.

Why Digital Protection Technologies

A DPO’s value rests on credibility, and credibility rests on qualifications and hands-on experience in the Jordanian market. Our team combines:

ISO/IEC 27701 Lead Implementer expertise for building a privacy information management system.
Deep familiarity with the EU General Data Protection Regulation for organisations serving European customers.
A working command of the Personal Data Protection Law and Central Bank of Jordan instructions, so global best practice is applied correctly in Jordan’s legal context.
Practical privacy programme management — data subject rights, DPIAs, and breach response.

Engagement models

Retained / fractional DPO

An ongoing, part-time appointment sized to your needs — the most common model for mid-size companies and fintechs that need an accountable officer without a full-time hire.

Project-based

A defined-scope engagement to stand up your programme, run a gap assessment and DPIAs, or prepare for a specific regulatory milestone.

Embedded support

We support and mentor an internal DPO or compliance lead, adding senior expertise and independent oversight to your existing team.

Frequently asked questions

What is DPO as a Service?

It is an outsourced arrangement where a qualified external specialist is appointed as your organisation’s Data Protection Officer. They build and monitor your compliance programme under the Personal Data Protection Law No. 24 of 2023, liaise with regulators, coordinate breach response, and train staff — on a fractional or retained basis instead of a full-time hire.

Is a DPO mandatory in Jordan?

Article 11/A of the PDPL makes appointing a DPO mandatory in six cases, including where a controller processes financial information or transfers data to databases outside the Kingdom. Because those two triggers apply to almost every bank, insurer, fintech, and payment provider, a DPO is effectively mandatory for CBJ-regulated organisations. Verify your specific position against the Official Gazette.

Can an outsourced DPO satisfy the legal requirement?

Yes. The law requires a competent, independent officer accountable for data protection; it does not require that person to be an employee. An external DPO can be formally appointed and is often more independent than an internal manager who also owns IT or operations.

How fast can you respond to a data breach?

Article 20 requires notifying affected data subjects within 24 hours and the Unit within 72 hours of a serious breach. Our engagement includes a breach-response process built to meet those deadlines, with escalation, assessment, and notification handled on your behalf.

Where can I read more about when a DPO is required?

Our informational guide explains, in plain terms, what a DPO is and when Jordanian law requires one. This page covers our commercial DPO service; contact us to discuss a scoped, retained or fractional appointment.

Request a DPO consultation

Talk to our team about an outsourced DPO appointment scoped to your organisation and sector. We serve banks, insurers, fintechs, and PDPL-covered organisations across Amman and the Kingdom.

Request a DPO consultation