How to build your data protection team

Author Tom Woods
August 4, 2025

Building an effective data protection function starts with the right people. As regulatory expectations rise and businesses face growing scrutiny around data use, many are reassessing how they structure their teams. Whether you’re hiring your second team member or scaling into a multi-role function, a clear approach to hiring data protection professionals is essential to getting it right.

When should you hire more data protection professionals?

You’ve made your first data protection hire, now comes the next step: building the team. Perhaps they’re a data protection officer (DPO), a privacy counsel or someone bridging both roles. Either way, the foundations are in place.

Every organisation builds differently. You may be responding to increased GDPR compliance demands, preparing for AI-related initiatives or reacting to a growing backlog of subject access requests, DPIAs or data breaches.

Each reason requires a different skillset. If your DPO has laid the legal foundation, the next hire may need to focus on operationalising it. This could involve managing processing activities, maintaining records of processing activities and leading on incident response. You may also need someone to help define your lawful basis for processing personal data and ensure that appropriate safeguards are in place when working with sensitive data.

If your team feels overwhelmed or reactive, you might need someone with strong data protection operations expertise. Consider how roles like privacy business partners or analysts can support subject access requests, privacy notices and risk assessment processes. If you’re exploring digital transformation, a counsel with experience working alongside product or engineering teams can help embed privacy by design from the start.

How to build a balanced data protection team

A common mistake is hiring someone with the same skillset as your first team member. This is understandable, especially if that person is high performing, but building an effective data protection team requires balance.

If your DPO is a strategic thinker but less detail-focused, consider someone who can deliver execution. If your first hire is legally trained, your next might come from cybersecurity, data governance or risk assessment.

If your team is made up of permanent staff, you might bring in a contractor to test a new data protection role or manage a short-term spike in demand.

Each hire should bring something new. Focus on filling capability gaps rather than repeating what’s already there.

Why privacy operations are essential for GDPR compliance

Data protection operations is often undervalued, but it’s essential for delivering compliance at scale.

This function is responsible for implementing data protection policies, managing tools and templates, supporting subject access requests and coordinating cross-functional workflows.

They often maintain up-to-date documentation required by the Information Commissioner’s Office (ICO), respond to personal data breaches and monitor internal data protection compliance.

Whether you call this role a data protection analyst, business partner or operations manager, their job is to translate legal advice into business action.

Hiring legal expertise without operational support is like hiring a chef without kitchen staff. Nothing gets delivered at scale.

What is the best team structure for data protection?

Your data protection team structure doesn’t need to follow traditional legal hierarchies. Some of the most effective teams are flat in structure but rich in function.

For example:
• A legal-leaning DPO or counsel
• A data protection operations lead or analyst
• A risk and governance specialist
• A business-facing partner embedded in product, tech or social media teams

This structure supports both data protection compliance and broader business engagement. It also allows for specialist growth without requiring people to take on management responsibilities if they prefer to deepen their expertise.

Do you need local or international data protection staff?

As your team grows, physical and jurisdictional coverage becomes more important.

Do you need all team members based in the UK? Could you benefit from hiring in the EU, where data protection laws and UK GDPR alignment still offer strong expertise?

Think about time zones, languages, local market needs and how information security is managed globally. Sometimes hiring a professional in a different region provides more value than stretching a local team too thin.

How to attract privacy professionals with the right hiring strategy

The data protection community is close-knit and observant. How you build and support your team will be noticed.

Engage with senior management, clarify your legal obligations and align on what a good data protection team looks like. Define the key roles, set realistic expectations and sense-check salaries before going to market.

A credible hiring process shows that your organisation values data protection compliance. It also reassures potential candidates that your privacy practices align with the expectations of the ICO and the wider data subject community.

What your data protection team structure says about your organisation

How you grow your data protection team communicates your organisation’s mindset.

A small, under-resourced team can suggest that data protection is viewed as a checkbox. A well-balanced team covering legal, operations and business needs signals genuine commitment to GDPR, data security and digital trust.

You don’t need to hire five people at once. But you do need a plan. And the sooner you define what good looks like, the easier it is to hire for it.

Need a sounding board?

I’ve helped organisations across industries scale from a single data protection hire to a fully functioning team. Whether you’re preparing for regulatory change, implementing a new privacy notice or planning for a data breach scenario, I can help shape the structure around your organisation’s data and obligations.

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