EU AI Act for Data Protection Officers
GDPR and the EU AI Act overlap precisely where AI meets personal data. As DPO you must ensure AI systems are documented in GDPR terms, DPIAs are carried out, and subprocessors are listed transparently. SimpleAct gives you the structural foundation to do that.
Typical challenges for DPOs
- AI systems appear in the processing register – but without a risk classification under the EU AI Act
- Who introduced which AI tool? Shadow AI is almost uncontrollable without a central inventory
- DPIA under Art. 35 GDPR for automated decisions – the data basis is missing
- Customers and clients ask whether all subprocessors are contractually covered
- The supervisory authority asks – and the DPO has no current, defensible overview
What this looks like in practice
The data protection authority asks whether a DPIA was conducted for the AI-assisted applicant tracking system. Without SimpleAct: three departments need to be queried individually about whether the system is high-risk, who the provider is, and what data is processed. With SimpleAct: the system is in the inventory, risk class is documented, subprocessors are listed – the DPIA data basis is ready.
What SimpleAct delivers for DPOs
Central AI inventory as data foundation
All AI systems in the organisation captured – with purpose, data types, processing location, and responsible parties. The foundation for DPIAs and the processing register.
Subprocessors made transparent
SimpleAct lists Hetzner (DE), Supabase (EU region Frankfurt), Stripe, and Brevo. DPA under Art. 28 GDPR is in place. No third-country transfer without safeguards.
Automated decisions documented
High-risk AI under the EU AI Act often intersects with Art. 22 GDPR. SimpleAct captures whether human oversight is in place – critical for DPIA justifications.
Append-only audit log
Every change to AI system data is timestamped and non-deletable – defensible for regulatory enquiries and GDPR subject access requests.
What you get as DPO
- Structured data basis for DPIA under Art. 35 GDPR
- Inventory of all AI systems including purpose and data types
- Subprocessor transparency with DPA documentation
- Evidence of human oversight for automated decisions (Art. 22 GDPR)
- Append-only audit log – timestamped, non-deletable
- EU hosting documented – no third-country transfer
Frequently asked questions from DPOs
Does every AI system require a DPIA?
Not automatically – but for high-risk AI under the EU AI Act, a Data Protection Impact Assessment under Art. 35 GDPR is frequently required. SimpleAct provides the structured data for it.
Where is customer data stored?
Application layer at Hetzner Nuremberg (Germany), database at Supabase EU region Frankfurt. No transfer to third countries.
Is SimpleAct itself GDPR-compliant?
Yes. DPA under Art. 28 GDPR is in place. Processing register, subprocessor list, and security whitepaper are available.
What is the difference between the EU AI Act and GDPR for AI?
GDPR governs data protection in the processing of personal data – including by AI. The EU AI Act additionally governs risk classification, documentation, and governance of AI systems regardless of personal data involvement. Both sets of requirements apply together for high-risk AI.
Who counts as a deployer under the EU AI Act?
Deployers are organisations that use an AI system under their own responsibility – regardless of whether they developed it. SimpleAct helps document these roles and responsibilities per system.
AI inventory and GDPR foundation in one
Create transparency across all AI systems – as the data basis for DPIAs, the processing register, and AI Act compliance.
Get started