What does an Article 27 Representative do?
An Article 27 Representative acts as a mandatory local contact in the European Union (EU) under EU GDPR or the United Kingdom (UK) under UK GDPR for organizations outside these regions that offer goods or services to, or monitor the behavior of, individuals located within the EU or UK, but do not have a physical presence there. This role helps ensure compliance by serving as a direct liaison for supervisory authorities and data subjects, and maintaining essential documentation such as Records of Processing Activities (ROPA).
If selecting an internal employee as your Article 27 Representative:
Your organization must formally appoint this employee in writing, clearly defining their responsibilities under GDPR (EU) or UK GDPR. This individual's name and local contact details must appear in your Privacy Policy, explicitly identifying their role as the EU and/or UK Representative. Your representative must reside within the EU or UK, respectively. If your business activities cover both regions, you must appoint representatives in both locations separately. You can upload this documentation to the EU Representative Appointed document in Vanta.
Note: If you do not have an internal employee that you can appoint, you can engage Vanta partners, such as GDPRLocal, to provide the representation service on your behalf.
Vanta’s recommendation:
While appointing an internal employee is possible, it is not a common practice due to the potential for conflict of interest, as well as operational complexity and increased legal responsibilities involved. A lot of companies that Vanta partners with typically appoint a third-party provider (such as GDPRLocal) or a qualified legal firm to provide Article 27 representation for compliance with GDPR.
If you have further questions about whether this requirement applies to your specific situation, we recommend consulting with your Legal Counsel.