https://ico.org.uk/for-organisations/guide-to-the-general-da...
Under the GDPR, you must appoint a DPO if:
you are a public authority (except for courts acting in their judicial capacity); your core activities require large scale, regular and systematic monitoring of individuals (for example, online behaviour tracking); or your core activities consist of large scale processing of special categories of data or data relating to criminal convictions and offences.
So - no?