I agree, and not only that, our solicitors advised us that by appointing a DPO when it's not needed we assume the responsibilities of companies who do need a DP

I agree, and not only that, our solicitors advised us that by appointing a DPO when it's not needed we assume the responsibilities of companies who do need a DPO. In other words, if you don't need a DPO you definitely shouldn't just appoint somebody because that feels like the right thing to do.