Personal Data: Appoint a DPO and a EU Representative in Sweden

Data Protection Officers (DPOs) according to GDPR

Under the General Data Protection Regulation (GDPR), a Data Protection Officer (DPO) is a mandatory role for organizations that engage in large-scale processing of personal data or handle sensitive data categories. The DPO is responsible for overseeing the organization’s data protection strategy and ensuring compliance with GDPR and related privacy regulations. This includes monitoring internal compliance, advising on data protection obligations, conducting data protection impact assessments (DPIAs), and acting as a point of contact for data subjects and supervisory authorities. The DPO must operate independently and with sufficient autonomy, expertise, and access to the organization’s leadership.

A Representative in the European Union, in accordance with Article 27 of the GDPR

Article 27 of the GDPR requires companies that are not established in the EU, but which offer goods or services to individuals in the EU or monitor their behavior, to appoint a representative within the European Union. This EU Representative acts as a point of contact for EU data subjects and supervising authorities and facilitates communication regarding data protection matters. The representative must be established in one of the EU Member States where the individuals whose data is processed are located and must be authorized in writing by the data controller or processor to act on their behalf with respects to GDPR compliance.

Companies that need to appoint a DPO and a EU Representative in Sweden

Companies operating in Sweden or processing the data of Swedish residents must ensure GDPR compliance , including the appointment of a DPO if their activities trigger the obligations under Articles 37 – 39 of the GDPR. Additionally, non-EU businesses offering services or monitoring individuals in Sweden must appoint an EU Representative located in Sweden under Article 27. This ensures proper local engagement with Integritetsskyddsmyndigheten (IMY), as the Swedish Supervising Authority, and effective communication with data subjects. Failing to meet these obligations can result in regulatory enforcement, fines, and reputational damage.

Lexing Sweden’s services in Sweden concerning the DPO role

At Lexing Sweden (Eris Law) we offer tailored and operational support for companies that need to fulfill the DPO and EU Representative requirements under the GDPR, such as:

• External DPO services
• Strategic Advisory services
• Privacy Audits
• Compliance Roadmaps
• DPIA evaluations
• Training
• Regulatory Liaison with Integritetsskyddsmyndigheten (IMY), the Swedish Supervising Authority on Data Protection
• Serve as designated EU Representative for businesses