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Does a small Swedish company need a data protection officer?

No, not merely because the company is small or processes personal data. An officer is required when the body is a public authority, when the core activity consists of regular and systematic monitoring of data subjects on a large scale, or when the core activity consists of large-scale processing of special categories of data or data on criminal offences. A company may appoint one voluntarily, and the same rules on position and tasks then apply.

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Source

Reference
GDPR (EU) 2016/679 Article 37, read together with the Swedish Data Protection Act (2018:218)
Acts
Dataskyddslagen
Area
Data protection and cybersecurity
Read date
2026-09-22

Read the source at the publisher · Dataskyddslagen

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