Our outsourced DPO service provides personal data protection expertise to help you monitor compliance, maintain records and handle requests as they arise. Clause 2, Article 33 of Law 91/2025/QH15 allows a business to engage a service provider instead of appointing its own staff; LexData sets out the point of contact, reporting schedule, coordination scope and each party’s responsibilities in writing.
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Article 57 of Decree 330/2026/ND-CP sets penalties relating to the appointment decision, staff qualifications, confidentiality undertakings and training. Article 58 separately governs the provision of personal data protection services. When setting up an outsourced model, distinguish the conditions that apply to in-house staff from those that apply to service providers.
Before choosing a DPO model, confirm whether you must appoint a data protection officer or unit, the qualification requirements and any exemption. Outsourcing needs a clear division of work, access to information and coordination with an internal contact.
LexData helps set up the monitoring schedule, obligations tracking and reporting on the agreed cycle. You remain responsible for implementation and for decisions within your authority; engaging a service provider does not transfer all legal responsibility to the provider.
What’s included
Who it’s for
Deliverables
How we work
We review your current status, dossiers and processing activities to prepare for activation.
Activate the DPO role within 1–2 weeks, set up contact channels and the operating model.
Monthly or quarterly support: monitoring compliance and acting as the data protection contact.
Periodic reports to management, updates on new regulations and recommendations to improve data protection processes.
Current compliance records, your internal contact, reporting needs and the expected volume of data subject requests.
The agreement specifies the assigned staff, access to information, reporting schedule, response times and substitution arrangements. We represent your business only within the authority you delegate.
FAQ
Yes. Clause 2, Article 33 of Law 91/2025/QH15 allows a business to appoint a data protection unit or officer, or to engage an organisation or individual providing the service. When engaging an organisation, review its capability profile (at least 3 qualified staff under Clause 2, Article 15), sign a service contract with a data processing agreement and disclose the provider’s details to data subjects (Clauses 1 and 3, Article 16 of Decree 356/2025/ND-CP). You may combine in-house staff with an outsourced service (Clause 4, Article 16) and remain responsible for your own compliance.
Under Clause 2, Article 33 of Law 91/2025/QH15, an organisation must appoint a qualified data protection unit or officer, or engage an organisation or individual providing the service. Eligible small enterprises and start-ups may choose not to perform Clause 2, Article 33 (together with Articles 21 and 22) for 5 years from 1 January 2026; medium-sized enterprises do not qualify. Household businesses and micro-enterprises have their own regime under Clause 2, Article 41 of Decree 356/2025/ND-CP. None of these categories is covered where the business provides personal data processing services, directly processes sensitive personal data, or has processed data of 100,000 or more data subjects in total. Confirm your category and activities before relying on an exemption; all other data protection obligations continue to apply.
Project consulting addresses a defined scope at one point in time, such as a gap assessment or a DPIA dossier. An outsourced DPO is an ongoing role: periodic monitoring, handling issues as they arise and keeping you compliant as processes, systems or the law change.
The scope is agreed in writing before the service starts: LexData is the point of contact and coordinator for matters within the service, while binding or strategic decisions are still approved by your business. This keeps roles clear and within authority.
Content last updated: .
Specific obligations and filings depend on your circumstances and the rules in force at the time. Official legal texts are in Vietnamese; English wording on this page is an unofficial explanation.
Further reading
Choosing between an outsourced DPO in Vietnam, an in-house data protection officer and the group's regional DPO: the Decree 356 conditions for each route, how a regional DPO can be used, conflicts of interest, dossier updates and the Decree 330 fines on each side.
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