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Re:Why It’s Hard for Startups to Create Wealth in Europe by M2Ys4U on Thursday October 03, 2019 @05:09AM (#21145022)
That's not what the GDPR says. There's no bright line for the number of employees handling data.

A DPO should be assigned if:

>(a) the processing is carried out by a public authority or body, except for courts acting in their judicial capacity;

>(b) the core activities of the controller or the processor consist of processing operations which, by virtue of their nature, their scope and/or their purposes, require regular and systematic monitoring of data subjects on a large scale; or

>(c) the core activities of the controller or the processor consist of processing on a large scale of special categories of data pursuant to Article 9 and personal data relating to criminal convictions and offences referred to in Article 10.

(Article 37)

And in any case a data protection officer is different from a representative, as the title of Article 27 indicates ("Representatives of controllers or processors not established in the Union").

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