The Business Guide To DPO Outsourcing In Malaysia

Starting 1 June 2025, Malaysian businesses that fall under the new Personal Data Protection Act 2025 thresholds must appoint a Data Protection Officer (DPO).  

While the most established of organisations may prefer appointing an in‑house DPO, most businesses will find outsourcing this role to seasoned professionals as the more cost‑effective and strategic approach. 

As a provider of outsourced DPO services ourselves, we have written this guide to help business decision makers: 

• determine if an outsourced DPO is the better option, and if yes, 
• key considerations and best practices to implement the role 

Let’s begin. 

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Clarifying the role of a DPO 

To paraphrase guidelines by the Malaysian Department of Personal Data Protection (PDP), a Data Protections Officer is responsible for ensuring the organisation’s total compliance with the PDPA, which means, among other duties:  

• implementing organisation-wide data protection policies 
• supporting Data Protection Impact Assessments (DPIAs) 
• serving as primary liaison with the Commissioner and data subjects, and  
• ensuring any data breaches or security incidents are promptly reported 

By law, a DPO must: 

• be a Malaysian resident for at least 180 days per year
• be fluent in both Bahasa Malaysia and English, and 
• possess expertise in Malaysian data protection laws and practices  

In addition, PDPD strongly recommends that a DPO should: 

• possess knowledge of the PDPA and relevant data protection laws 
• understand your business operations and personal data processing activities 
• understand information technology and data security 
• demonstrate professional integrity, and
• have the ability to promote a culture of data protection within the organisation 

It is a specialised role that demands technical expertise and ethical conduct, and with enforcement starting 1 June 2025, a critical hire for businesses. 

Signs you need an outsourced DPO 

The first step is to assess if the team has the capacity to meet the PDPA’s requirements without outside help, and here are five key indicators it likely does not: 

1. No one in the organisation has the requisite data privacy knowledge
2. No internal staff member meets the PDPA’s DPO qualification criteria
3. The organisation doesn’t have the capacity to train an internal candidate or evaluate a new hire
4. Qualified team members are engaged in roles that use personal data for commercial gain, leading to a potential conflict of interest
5. There is a company-wide lack of understanding about the PDPA and data protection.

If any of these applies to your organisation, there is a strong argument to outsource your DPO role. 

Even if you intend to build in-house DPO capacity in the future, an outsourced DPO can ensure immediate compliance with the June 2025 deadline. 

How to properly outsource your DPO role 

PDP recommends a minimum DPO appointment term of two years to promote stability, and to effectively outsource this role, your organisation should: 

1. Formalise the appointment of DPO through a written service contract
2. Register the appointed DPO within 21 days from the date of appointment using the SPDP system 
3. Set up an official business email for the DPO (e.g., [email protected]) to serve as the main channel for all data protection-related communications 
4. Maintain clear documentation of all communications, compliance reports, breach logs, and audit records prepared or reviewed by the outsourced DPO 

The service contract should clearly define the DPO’s scope of work, service terms, responsibilities, and access to data. 

Best practices when outsourcing 

To make the most of your outsourced DPO, you can consider these operational best practices: 

Conclusion 

If your organisation lacks the people, structure, or independence needed to manage a compliant data protection programme internally, outsourcing your DPO is a strategic, risk-managed solution aligned with regulatory expectations. 

 We can help you draft compliant service agreements and ensure your appointment meets PDPA expectations. Reach out to get started.