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data protection representative

Suvitha
Suvitha
Suvitha is a Regulatory Compliance Expert and Content Strategist with a deep understanding of UK and EU regulatory frameworks. At Euverify, she transforms complex legal and technical updates into clear, actionable guidance for businesses. Her work bridges regulation and communication, helping brands stay compliant, credible, and competitive in regulated markets.
January 5, 2026

New EU and UK Enforcement Actions Spotlight the Need for a Data Protection Representative

Recent enforcement activity by EU and UK data protection authorities shows that GDPR rules are being actively checked, not just published and forgotten. Regulators are taking a closer look at how businesses handle personal data and whether a Data Protection Representative has been properly appointed. This is now a common focus during compliance reviews.

For businesses selling physical products into the EU or UK from outside these regions, appointing a GDPR Representative under Article 27, sometimes informally referred to as a Data Protection Representative, is becoming a practical step that needs to be addressed early rather than only when questions arise.

What Is Meant by Enforcement Action?

An enforcement action is what happens when a regulator takes a closer look at a business and notices that data protection rules are not being followed properly. Regulators will often check whether an EU data protection representative has been appointed when the business is required to have one.

Depending on what is found, this can lead to:

  • Formal warnings or written notices

  • Requests to fix specific compliance gaps

  • Financial penalties in more serious cases

  • Continued follow-up from the authority

Why Data Protection Representatives Are Under Closer Review

Under EU GDPR and UK GDPR, certain businesses are required to appoint a data protection representative. An EU data protection representative acts as the official local contact for regulators and individuals. When this role is missing, authorities have no clear way to communicate with the business, which is why it often leads to enforcement attention.

This requirement usually applies to businesses that:

  • Are established outside the EU or UK

  • Offer goods or services to individuals in the EU or UK

  • Monitor the behaviour of people in these regions

What a Data Protection Representative Actually Does

A Data Protection Representative acts as the official, legally recognised contact point between a business and data protection authorities in the EU or UK. When regulators need information, raise concerns, or issue formal notices, the representative is the first point of contact.

In practical terms, this role includes:

  • Receiving enquiries, notices, and requests related to data protection

  • Passing these requests to the business and helping ensure they are addressed properly

  • Acting as a contact point for individuals with questions about how their personal data is handled

Using professional data protection services helps demonstrate to regulators that a business understands its obligations under GDPR and has taken steps to meet them. It also prevents situations where authorities are unable to contact a company because it is based outside their jurisdiction.

This role does not replace internal compliance work. The business remains responsible for data protection, while the representative provides a required local point of contact under EU GDPR and UK GDPR.

How Euverify Supports Compliance Needs

Euverify helps businesses selling physical products into the EU and UK manage compliance in a clear, practical way. The platform and services are designed to support day-to-day regulatory requirements without unnecessary complexity.

With Euverify, businesses can:

  • Upload product details and keep records organised

  • Create and store compliance documents and technical files

  • Maintain clear documentation for regulators, customs, and marketplaces

Authorised representative support

Where required, Euverify provides UK and EU authorised representative services for product compliance purposes. An authorised representative acts as a local contact for regulators in relation to product documentation, conformity, and safety obligations. This role is separate from the GDPR Article 27 Data Protection Representative, which covers data protection obligations and communication with data protection authorities.

 

Support for essential compliance documents

Correct paperwork is essential when selling products in the EU and UK. Euverify supports this by providing tools and templates for key compliance documents, including guidance on preparing an EU EC Declaration of Conformity.

What Businesses Should Do Next

If your company sells products into the EU or UK, it is worth taking a moment to review your current compliance position. Practical next steps include:

  • Checking where your business is legally established

  • Reviewing whether you process personal data of EU or UK residents

  • Confirming whether a Data Protection Representative or local contact is required

  • Making sure compliance documents and legal contacts, including any Data Protection Representative, are up to date

For more specific guidance or to discuss the next steps for your business, you can contact the Euverify team directly.

FAQs

  1. What recent EU and UK enforcement actions have increased Article 27 checks?
    Cases where non-EU and non-UK companies operated without a required Article 27 Representative.

  1. Which non-EU and non-UK companies are most likely to be checked?
    Online businesses selling to or collecting data from EU or UK users.

  2. How does failing to appoint an Article 27 Representative create risk?
    It is a GDPR breach that can lead to warnings, orders, or fines.

  3. What do regulators ask for during Article 27 checks?
    Proof of a representative, privacy policy details, and data processing records.

  4. How does appointing a GDPR Representative help?
    It gives regulators a local contact and helps show compliance.

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