Outsourced DPO · UK GDPR · ICO Accountability

A retained Data Protection Officer, without the cost of hiring one.

Specialist UK GDPR compliance for SMEs. Banking-grade data protection experience, applied to your organisation as a named, accountable DPO at human scale.

Matthew Varnham
Founder & Principal

Eight years at the data protection function of a top-five UK bank. Built around continuity of relationship — the person who writes the services agreement is the person who attends your governance meetings and signs your assessments.

CIPP/E · CIPM · ICO Registered
8 yrs UK Banking · East Midlands
of VARNHAMCONSULTING
Established 2026 · Registered with the ICO · Professional indemnity insured
— The challenge

Data protection compliance shouldn't keep you up at night.

Most UK SMEs know they have obligations under the UK GDPR. Few have the specialist resource to manage them with confidence. The four most common patterns I encounter:

01

No one owns it

Data protection responsibility falls to whoever has time — often a director already stretched across the business. The ICO expects more.

02

DSARs pile up

Subject access requests carry a one-month statutory deadline. Without a process, they become a compliance crisis waiting to happen.

03

Breach anxiety

When a breach occurs, you have 72 hours to assess and notify the ICO. Without a plan, panic replaces process.

04

Regulatory change

The DUAA, new complaint handling requirements from June 2026, evolving ICO guidance — keeping up is a full-time job.

— How it works

From uncertainty to confidence.

Step 01

Initial assessment

I assess your compliance posture against the ICO's Accountability Framework, identify gaps, and map your processing activities. Output: a written baseline against which everything else is measured.

Step 02

Tailored roadmap

You receive a prioritised plan — policies, procedures, training, breach preparedness — with clear timescales and ownership. The plan is sequenced so quick wins land first and structural work follows.

Step 03

Ongoing DPO support

Your retained DPO manages compliance continuously: DSARs, incidents, advisory, training, governance, and regulatory monitoring. The relationship is embedded, not transactional.

— Services

Everything you need for UK data protection compliance.

Flexible services that scale with your organisation — from a full retained DPO function to standalone compliance projects.

— VAR/SVC/RT

Retained DPO service

A named DPO embedded in your governance — available when you need them, at a fraction of the cost of hiring. Three tiers, fixed monthly fees, agreed at engagement.

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— VAR/HC

Compliance health check

A structured assessment against the ICO's Accountability Framework with a prioritised action plan. The fastest way to know where you stand.

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— VAR/PDB

Breach management

Incident response from detection through ICO notification, data subject communication, and root-cause analysis. Available on retainer or as standalone engagement.

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— VAR/DSAR

DSAR management

Support with end-to-end handling of data subject rights requests within the statutory timescale. From triage to response, with full evidential record-keeping.

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— VAR/TR

Staff training

UK-specific data protection awareness training — live, recorded, or e-learning — tailored to your sector. Reviewed and signed off personally.

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— VAR/AN

Policies & documentation

Privacy notices, data protection policies, DPIAs, DPAs, retention schedules — everything the ICO expects, written for the people who actually use them.

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— Why this consultancy

Deep specialist experience, not a generalist firm.

Eight years of data protection in UK banking — managing high-volume DSARs, dual FCA/ICO reporting, international transfers, and breach response at scale. That depth of experience is what separates this consultancy from generalist providers.

Most SMEs do not need banking-grade compliance machinery. They need access to the judgement that comes from having operated it.

More about Varnham Consulting →
£100k+
Typical all-in cost of an in-house DPO appointment, before recruitment, training, NIC, pension, and turnover risk. Banking-sector benchmarks sit closer to a quarter of a million.
72hrs
ICO breach notification window from awareness
1month
DSAR statutory response deadline under UK GDPR
19June
DUAA complaint handling deadline · 2026
— Sectors served

Specialist depth across the sectors most exposed to UK GDPR.

01

Healthcare & social care

Special category data, safeguarding overlays, CQC and ICO dual reporting, complex DSARs across clinical records.

02

Financial services

FCA-and-ICO dual reporting, banking-grade DSAR handling, breach response under regulatory scrutiny — direct sector experience.

03

Technology & SaaS

Article 28 processor compliance, AI and Article 22 obligations, evidence the procurement teams of your enterprise clients require.

04

Recruitment & staffing

The sector with the highest density of UK GDPR failure modes — candidate data, retention windows, lawful bases.

05

Charities & not-for-profits

Vulnerable beneficiary data, trustee-led governance, funder data sharing — informed by trustee experience on multiple boards.

06

Professional services

Solicitors, accountants, surveyors, IFAs. Conflict-checking, retention against the Limitation Act, dual controller-processor compliance.

07

Education

Children's data under the ICO's Age Appropriate Design Code, safeguarding records, parental consent, SEN data sharing.

08

Other UK SMEs

Organisations of 10–250 employees with a meaningful UK GDPR footprint. Engagement is referral-led where the brief is genuinely substantive.

All sectors in detail →
— Start here

The compliance health check.

Eleven assessment areas mapped to the ICO's Accountability Framework, returned as a written report with a prioritised action plan. The right starting point for most organisations — and the way most retainers begin.

Take the health check →
11areas
Mapped directly to the ICO Accountability Framework, including DUAA readiness
14days
From engagement to written report, including a 60-minute walkthrough
£1,500
Fixed fee, fully credited against any retainer that follows — effectively free for retainer clients
DUAAaware
Specific assessment of readiness for the 19 June 2026 deadline
— Get in touch

If we have been introduced, please be in touch.

Most engagements come through referral. If a colleague, adviser, or board peer has suggested you reach out, the easiest first step is a thirty-minute conversation — no charge, no obligation.

Use the intake form to start. A short intake is the entry point — name, email, phone, and the nature of your enquiry. Once you have submitted, you will receive a follow-up email confirming next steps within one working day.

— Start the conversation

A short intake form, then a tailored next step.

The form takes under two minutes. After you submit, I will respond within one working day with the right next step for your situation.

01
You complete the intake. Name, email, phone, nature of enquiry.
02
I respond personally within one working day. With the right next step — call, questionnaire, or direct response.
03
If we proceed, we proceed. No automated marketing, no follow-up sequence.
Open the intake form →