Appointing EU Representative
Guides appointment of GDPR Article 27 EU representative for non-EU controllers or processors. Covers criteria, responsibilities, and documentation. Activate when a non-EU entity processes EU data. Keywords: EU representative, Article 27, non-EU controller, territorial scope.
Appointing EU Representative
Overview
Article 27 requires controllers or processors not established in the Union but subject to GDPR under Art. 3(2) to designate a representative in a Member State where affected data subjects are located.
Implementation Approach
Phase 1: Assessment
- Review current state against applicable GDPR articles.
- Identify gaps between current practices and requirements.
- Classify gaps by severity and regulatory risk.
- Document the assessment with evidence references.
Phase 2: Design
- Design measures to address identified gaps.
- Align measures with organisational capacity and risk appetite.
- Obtain DPO and stakeholder review of proposed measures.
- Create implementation timeline with milestones.
Phase 3: Implementation
- Execute the implementation plan according to priority.
- Document all measures implemented with evidence.
- Train relevant staff on new procedures and requirements.
- Validate implementation through testing or review.
Phase 4: Maintenance
- Schedule periodic reviews (minimum annual).
- Monitor for regulatory changes affecting the scope.
- Update measures in response to audit findings or incidents.
- Report on compliance status to the governance structure.
Added: September 23, 2026 · Last updated: October 13, 2026
Files (5)
- Jurisdiction
- General
- Practice area
- Data protection
- License
- Apache-2.0
- Author
- mukul975
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