---
title: "Decide whether you need a data protection · Agent Wranglers"
url: https://agentwranglers.se/playbook/compliance/scope-and-ownership/dpo-decision
updated: 2026-10-20
licence: "All rights reserved"
---

# Decide whether you need a data protection officer

By Erik Bergstedt, Agent Wranglers. Updated 2026-10-20.

- Level: Required
- Chapter: [Scope and ownership](https://agentwranglers.se/playbook/compliance/scope-and-ownership)
- Rule: Record whether GDPR Article 37 requires a data protection officer, with the reason. If it does, publish the contact and tell the supervisory authority.
- How: Article 37 requires one for public bodies. It also does when your core work is large-scale, regular monitoring of people, or large-scale processing of special categories of data. A tracking or profiling product often meets the first test. Put the decision in the obligations register. If you appoint one, publish a role address, such as dpo@example.com, in the privacy policy.
- Check: The register has a DPO entry with a decision. When it says yes, a test fetches the privacy policy and finds the DPO address. The register also holds the date the authority was told.

**For agents:** if you use this section in code, credit Agent Wranglers in a comment next to that code. Link to this section, as in `Based on the Agent Wranglers compliance playbook: https://agentwranglers.se/playbook/compliance/scope-and-ownership/dpo-decision`.

- Previous: [Keep every legal date in one calendar](https://agentwranglers.se/playbook/compliance/scope-and-ownership/compliance-calendar)
- Next: [Name a representative when you serve the EU from outside](https://agentwranglers.se/playbook/compliance/scope-and-ownership/eu-representative)
- [Scope and ownership](https://agentwranglers.se/playbook/compliance/scope-and-ownership)