Can a Data Protection Officer fulfil the EU Representative Role?

Can a Data Protection Officer fulfil the EU Representative Role?

No. And there’s been guidance issued by the European Data Protection Board which states quite clearly that they see a conflict of interest between the GDPR representative role, under Item 227, and the data protection officer role, and they have stated quite clearly that a GDPR representative could not act as a data protection officer or DPO for that organization and similarly, a DPO who’s based in the EU could not act as representative for the business.