How do the DPO and EU representative interplay?
The GDPR applies to controllers and processors that process personal data of individuals in the EU, regardless of where the organization is established in the world. Those organizations that are not established inside the EU are required to appoint a representative who is established in the EU for purposes of GDPR compliance. The GDPR also requires a data protection officer under some circumstances, and makes the role voluntary otherwise, and the Article 29 Working Party recommends the DPO be located within the EU for accessibility even if the controller or processor is not.
