Alternative to DataGuard for SMEs: Compliance Beyond the DPO

DataGuard has positioned itself in the German-speaking market as a combined data protection and information security platform, addressing primarily the Data Protection Officer (Art. 37 GDPR · § 38 BDSG) and the Information Security Officer (ISO/IEC 27001:2022 · §§ 30, 38 BSIG). The offering comprises both software and external officers in a managed service model – an approach that works for companies with a manageable compliance scope.

Mid-sized companies with 100 to 1,000 employees in Germany, however, frequently face a broader obligation profile: alongside data protection and IT security, appointment obligations for occupational safety (§ 5 ArbSchG), fire safety (DGUV I 205-023), hazardous substances (§ 6 GefStoffV) or – depending on sector – supply chain (§ 4 LkSG) or anti-money laundering (§ 7 GwG) must simultaneously be fulfilled. This article analyses whether and when DataGuard is sufficient for SMEs and what structural alternatives fully map the officer landscape.

DataGuard combines a SaaS platform for data protection and information security management with a network of external officers. The strength of the offering lies in the depth of the DPO and ISB function: structured records of processing activities, DPIA workflows, ISO 27001 readiness tools and a consultant network for the appointment function.

For companies whose compliance requirements are concentrated on these two roles – typically digital service providers, fintech companies or data processors – this focus is appropriate. The platform was built from the ground up for these two disciplines and maps them with corresponding depth.

The limitations become apparent when the company must cover additional officer roles. A pharmaceutical company with 400 employees typically has, in addition to DPO and ISB, a Hygiene Officer (§ 36 IfSG · KRINKO), a Radiation Protection Officer (StrlSchG · StrlSchV) and possibly an ESG Officer (CSRD · ESRS). A logistics company additionally requires a Dangerous Goods Officer (§ 3 GbV · ADR). These roles are not natively mapped in DataGuard – neither as a workspace module nor as an appointment service.

This is not an omission but a deliberate product decision. For mid-sized companies that wish to manage their entire officer portfolio in one system, this creates a structural problem: they combine DataGuard for DPO and ISB with separate solutions for the remaining roles.

This fragmentation effect is costly in practice: different contacts, different report formats and no overarching audit log. In a company-wide compliance audit, management must consolidate evidence from multiple systems – an effort that can be avoided with an integrated platform.

The number of relevant officer roles depends on company size, sector and business model. As a guide: a manufacturing company with 250 employees typically has at least six to eight mandatory officers. A retail company with 500 employees has four to six. A financial services provider with 50 or more employees has three to five.

The regularly relevant roles in German SMEs are: Data Protection Officer (Art. 37 GDPR), Information Security Officer (§§ 30, 38 BSIG), Occupational Safety Specialist (§ 5 ArbSchG · DGUV Regulation 2), Fire Safety Officer (DGUV I 205-023 · DIN 14095), and depending on sector, Hazardous Substances Officer (§ 6 GefStoffV), Anti-Money Laundering Officer (§ 7 GwG) or Supply Chain Compliance Officer (§ 4 LkSG).

Added to this are statutory training obligations: each officer must not only be appointed but must regularly exercise their function with demonstrable qualification. DGUV Regulation 2 prescribes specific deployment times for the Occupational Safety Specialist. § 38 BDSG requires expertise of the Data Protection Officer. For the Anti-Money Laundering Officer, BaFin interpretive and application guidance prescribes regular training.

This means: even a smaller mid-sized company manages in total several officer mandates with different legal requirements, different audit cycles and different reporting lines. A platform covering only two of them cannot consolidate the complete compliance documentation in one system.

Check concretely for your company: what appointment obligations exist under current law? The answer depends on headcount, sector, type of operation and business model. A complete inventory is the first step – regardless of which platform is ultimately chosen. Anyone starting with an incomplete list will inevitably choose an unsuitable tool.

The market for external compliance support is structurally divided into three categories: data protection-focused platforms (DataGuard, similar DPO providers), role-specialised individual providers (e.g. external occupational safety services, fire safety planning offices, hazardous substances consultants) and cross-role officer platforms.

The structural weakness of the role specialist model shows up at audit preparation: when each role is documented in a different system, overarching evidence is missing. The auditor requesting the compliance record for the entire company does not receive a consolidated overview – but must switch between five different systems and contacts.

Relevant for the decision: first count your actual officer roles. If the result is two roles, DataGuard is an appropriate choice. If it is five or more, the comparison starts from a different point. The comparison matrix helps to identify the right provider class – before comparing individual products against each other. This first filter saves evaluation effort and leads more quickly to the right provider group.

The statutory officer mandate is not an informal arrangement. It begins with the formal appointment: written mandate, defined reporting line, deputy arrangement for absence. For the Data Protection Officer, Art. 37 para. 1 GDPR prescribes formal appointment; for the Occupational Safety Specialist, § 5 ArbSchG; for the Anti-Money Laundering Officer, § 7 GwG.

Beyond this, the mandate must be operationally lived: regular reviews, training, reporting to management, documentation of incidents and measures. The supervisory authority checks not only whether an officer has been appointed, but whether they have actually and demonstrably exercised their function. The deadline runs from awareness – and the evidence must be retrievable retrospectively.

This means for software selection: a system that only files the appointment certificate but does not structure the operational work creates half-finished compliance. A system that structures the operational work well but does not map the formal appointment documentation has the same weakness from the other side.

CIVAC maps the complete cycle: appointment certificate, reporting line, operational tasks (Tasks surface), training records (Training surface), audit results (Projects surface) and monthly documentation consolidation (Documentation surface). All six surfaces of the workspace interlock and produce an audit-proof evidence path that follows the same logic for each of the 25 roles.

Concretely for management: a call from a supervisory authority does not lead to a multi-hour search in different systems. The auditor calls and the evidence is ready – structured, cross-role, without manual consolidation. That is the operational standard that a complete appointment model enables.

DataGuard has built recognised product depth in the DPO function: structured records of processing activities (RPA) under Art. 30 GDPR, data protection impact assessments (DPIA) under Art. 35 GDPR, automated data subject rights workflows under Art. 15–22, and an external consultant network for formal appointment under Art. 37 GDPR. This is factual strength that should be acknowledged.

What is missing in a data protection-focused model are the cross-cutting functions that play a role at an inspection visit: how is the Data Protection Officer connected to the ISB? What is the connection between the DPIA result and information security risk management under ISO/IEC 27001:2022? What training has been documented for the Fire Safety Officer and the Anti-Money Laundering Officer? These questions cannot be answered from a purely data protection-oriented system.

For mid-sized companies undergoing a data protection audit by the state data protection authority or a GDPR audit by a business partner, DataGuard is appropriate. For companies seeking ISO/IEC 27001:2022 certification, preparing a NIS-2 applicability check (§§ 30, 38 BSIG) or needing to demonstrate supply chain due diligence to the BAFA under the LkSG, a DPO-focused system is structurally insufficient.

A concrete example: the supply chain due diligence record under §§ 4–10 LkSG requires a documented supply chain risk analysis, a complaints mechanism and regular reports to the BAFA. These are independent obligations that cannot be mapped in either a DPO workspace or an ISB tool – but require a role-specific structure for the Supply Chain Compliance Officer.

Both DataGuard and CIVAC cover DPO and ISB – the difference lies in completeness. The Information Security Officer (ISB) under §§ 30, 38 BSIG and ISO/IEC 27001:2022 has a close operational connection to the DPO: DPIA results feed into ISMS risk management, data breaches under Art. 33 GDPR must be reported within 72 hours and simultaneously trigger BSIG notification obligations, information security training partially covers the same target audience as data protection training.

A platform that maps both roles and structures the connection points substantially reduces effort: a single training event can be documented for both roles, a security incident automatically generates entries in the DPO log and the ISB incident register, the annual report contains sections for both officer functions.

The CIVAC workspace maps exactly these connections – not as a special function but as the fundamental architecture of the system. The 93 implemented controls under ISO/IEC 27001:2022 are linked to the DPO review points. The NIS-2 24/72-hour notification chain is pre-installed as a task template. The ISMS is GDPR-native, not retroactively linked.

For mid-sized companies wishing to combine DPO and ISB – which is legally permissible and common in practice – the integration of these two roles in one workspace is a concrete operational advantage over parallel management in two systems.

Important note: combining DPO and ISB in one person is only permissible if there is no conflict of interest. In a company where the prospective DPO/ISB is simultaneously responsible for IT operations – and would thus be reviewing their own work – this would be problematic. For many mid-sized companies, outsourcing both functions to external officers via a single provider is the cleaner solution.

DataGuard uses a subscription model oriented to company type and scope of service. Publicly available price indications vary depending on the provider model and contractual terms. External DPO services are typically billed as a monthly flat rate in addition to the platform licence.

For mid-sized companies requiring multiple external officers, a cumulative cost comparison arises: one DPO with a specialist, one ISB with another, an external Occupational Safety Specialist via an occupational health and safety service company, a Fire Safety Officer via a planning office. The sum of these individual contracts generally exceeds the costs of an integrated platform with a network solution.

The actual cost argument, however, lies not in the licence price but in the administrative effort. Multiple external officers in multiple systems mean: multiple contacts, multiple reporting lines, multiple year-end documentations, multiple system maintenance tasks. For management without its own compliance department, this is a considerable time investment that is often not realistically reflected in practice.

An integrated model – workspace licence for internal officers plus appointment service for external – consolidates this effort into one system, one contact and one audit log. That is the objectively relevant unit of comparison, not the monthly licence price alone.

When comparing platforms, also calculate the indirect costs: how much working time is spent per month on coordinating external officers, consolidating reports and preparing audit documents? These hours are not reflected in any licence fee – but are indispensable in a full cost analysis.

Companies wishing to switch from DataGuard to another platform face similar questions as with any system change: what must be migrated, what can be rebuilt, and how is continuity of the documentation chain ensured?

Particularly relevant in a DPO system change is the transfer of the record of processing activities (RPA) under Art. 30 GDPR. The RPA is an ongoing obligation that cannot start from zero. Completed DPIA reports must remain retrospectively retrievable. Training records must remain documented even if the operational training platform changes.

A pragmatic migration path: the new system is used for all new activities, while legacy data from DataGuard is archived in export format or in a separate DMS. The formal appointment certificate of the new external officer replaces that of the old one from the handover date – with the handover record itself needing to be documented.

CIVAC supports the onboarding process with a structured two-working-day path for formal appointment: contract, person, certificate. The officer role is thereby formally filled and documented within two working days of contract conclusion – rather than after the classic lead time of 2 to 6 weeks that external service providers frequently require.

For companies that want no system break, a targeted migration strategy is recommended: first set up the new roles in the CIVAC workspace, then gradually replace the DataGuard functions, and finally transfer the RPA. The risk of an uncontrolled data protection incident during the transition phase can thus be minimised.

DataGuard is a solid platform for companies whose compliance requirements are concentrated on data protection and information security. For pure technology companies, software providers and data processors without physical production, hazardous substances or specific sector obligations, this focus may be sufficient.

For German SMEs in manufacturing, logistics-intensive, finance or health-adjacent sectors, this focus is structurally insufficient. The mandatory officer landscape is broader, auditors come from more than one authority and the audit log must map more than two roles.

The objective decision question is: how many officer roles does your company have, and how many of them are filled externally? Anyone with two roles can use a specialised provider. Anyone with five or more roles who wishes to consolidate them in one system – internally, externally or in a hybrid arrangement – needs a platform that maps all roles with equal depth.

Licence the workspace for your internal officers or appoint our officers. The CIVAC model as a compliance platform and Officer-as-a-Service enables both in one system, with one audit log, one reporting line for management. Appointment certificate, signed, filed, verifiable. That is the standard against which every compliance platform should be measured.

If you wish to examine which model is appropriate for the officer landscape of your company, contact the CIVAC team. A structured initial consultation helps clarify the starting position and define the appropriate combination of workspace licence and appointment service. Turn reading into action. Contact: info@civac.de.