GDPR EU Representation

Answer:

You are only exempted for appointing a representative if the processing, which is occasional, does not include on a large scale the processing of special categories of data, as referred in Article 9(1) or processing of personal data relating to criminal convictions and offences referred in Article 10, and is unlikely to result in a risk to the rights and freedoms of natural persons, taking into account the nature, context, scope and purposes of the processing; or if you are a public authority or body (which is not the case).