Where should your EU Data Representative be located?
There’s quite a bit of discretion around this. The only absolute rule is that there needs to be at least one or some data subjects in the EU member state in which the representative is appointed. But once that is the case, and there is no hard and fast rule and you can select the member state that suits you best. It has been suggested that best practice might be to appoint the representative in the member state where most of your data subjects are located. But that’s not a hard and fast rule. Once you have a representative in one member state where you have at least one or some data subjects that will cover you for the entire of the EU.