Named contact
The point of contact for the Commissioner and for individuals exercising their rights.
Data Protection Officer as a Service (DPOaaS)
An external, certified Data Protection Officer who carries the duties Malaysia's PDPA requires, so you meet the rules without hiring a full-time DPO.
The DPO requirement in numbers
1 June 2025DPO appointment became mandatory for organisations that meet a threshold.
20,000individuals whose personal data you process, one of the three triggers.
10,000individuals whose sensitive personal data you process, another trigger.
21 daysto notify the Commissioner of your DPO appointment (JPDP Circular No. 2/2025).
72 hoursthe response window your DPO prepares you to meet if a breach occurs.
RM2,000a month is where DPO as a Service starts; final fee is scoped to you.
What is DPO as a Service?
What it is
An outsourced arrangement in which an external certified Data Protection Officer discharges the duties the PDPA requires, without the organisation hiring a full-time DPO. The outsourced DPO becomes the named contact for the Commissioner and for individuals, advises management, keeps policies and records current, runs reviews and training, and leads the response to a personal data breach.
Who stays accountable
You do. The organisation remains accountable for compliance. The DPO makes sure you have the advice, processes and evidence to meet it, and that someone qualified is watching the obligations between audits.
What an outsourced DPO does for you
Certified DPOs who work to the PDPA and cross-border requirements, with monthly reviews, audits, training, breach response and regulatory liaison.
Advice to management
Plain-language advice on your PDPA obligations, so decisions are made with the Act in view.
Policies and records
Keeps privacy notices, policies and processing records current as your business changes.
Reviews and audits
Periodic reviews that test what you do against what you say, with findings tracked to close.
Staff training
Awareness sessions for the people who actually handle personal data.
Breach response
Leads the response when a personal data breach occurs, including regulatory liaison.
Who needs to appoint a DPO in Malaysia?
Meeting any one of these conditions can require an appointment. Fintechs, e-commerce and other data-heavy businesses often do.
Over 20,000 individuals
You process the personal data of more than 20,000 data subjects.
Over 10,000 sensitive
You process sensitive personal data, including financial information, of more than 10,000 data subjects.
Regular, systematic monitoring
Your processing involves regular and systematic monitoring of personal data.
The DPO can be an existing employee or an outsourced provider under a service contract, provided they are proficient in both Malay and English and resident in Malaysia or easily contactable.
How DPOaaS works
01
Assessment
Gap analysis and data mapping to see where your PDPA risks are.
02
Appointment
We designate a certified DPO for you and notify the Personal Data Protection Commissioner (JPDP) within the 21-day window.
03
Management
Policies, requests from individuals, compliance monitoring and incident response.
04
Training and updates
Staff education, privacy impact assessments and ongoing adherence reviews.
FAQ
A data controller or data processor must assess three alternative conditions: personal data processing exceeding 20,000 data subjects; sensitive personal data including financial information exceeding 10,000 data subjects; or processing activities requiring regular and systematic monitoring of personal data. Meeting any one can require appointment.
Yes. JPDP's DPO guideline allows the DPO to be an existing employee or an outsourced provider appointed under a service contract, provided the DPO is proficient in both Malay and English and is resident in Malaysia or easily contactable. Outsourcing does not transfer the organisation's accountability for its personal data processing.
OrbixTech's DPO as a Service starts from RM2,000 a month. The final fee depends on how much personal data you process, how complex that processing is, and how much of the DPO's time the role genuinely needs, so it is scoped after the initial assessment rather than quoted blind. Where the engagement includes staff training, that component may be HRD Corp claimable, subject to programme and employer eligibility.
No. The sensitive-data condition and the independent regular and systematic monitoring condition must also be assessed. Exactly 20,000 does not exceed the general numerical threshold, but another condition may still apply.