The data protection officer does not have to be a full-time role. It can be part of someone's other duties, or performed by a contractor (Art 37 ¶ (6): https://

The data protection officer does not have to be a full-time role. It can be part of someone's other duties, or performed by a contractor (Art 37 ¶ (6): https://gdpr-info.eu/art-37-gdpr/ https://gdpr-info.eu/art-37-gdpr/).