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Code of conduct: the DPO and the core value “professionalism”

Ethics Working Group

In December 2018, the members of the Ethics Working Group of the DPO of Duthler Academy, in collaboration with Duthler Associates, published the Code of Conduct for Data Protection Officer (DPO). This took the lead in drawing up rules of conduct for the professional group to support the DPO in his daily practice. A practice in which the DPO is regularly confronted with dilemmas.

As stated at the time of publication, the Code of Conduct is not set in stone. The working group is open to criticism and would like to have a discussion. The rules of conduct are based on core values. In this blog, we want to take a closer look at the rules of conduct based on the core value of “professionalism”.

What are the core value of professionalism?

The core value of “professionalism” is described in the Code of Conduct document as follows:

  • In-depth knowledge and continuing education, extensive experience, skills and competences;
  • Maintaining the right balance between supervisor, advisor and cooperating foreman; and
  • Recognize limits to his expertise and know when to get help.

Code of conduct

Based on this core value, the following rules of conduct have been described:

  • The DPO must perform his legal task carefully;
  • In the performance of his duties, the DPO acts in accordance with the standards that give substance to the professional standard, including in particular laws and regulations, guidelines from supervisors and ethical rules of conduct;
  • The DPO will explicitly document the decisions on the basis of which an assessment has been made and will be transparent about this, especially in the event that an advice from the DPO is not followed;
  • The DPO maintains his “professional competence” at the level required to perform his duties adequately; and
  • The DPO must be aware of the limits of his expertise and professional responsibility and, where necessary, request the help of others.