Guidelines on Data Protection Officers (‘DPOs’) (wp243rev.01)
Section 5.10 What are the safeguards to enable the DPO to perform her/his tasks in an independent manner? What does ‘conflict of interests’ mean?
Several safeguards exist in order to enable the DPO to act in an independent manner:
no instructions by the controllersor the processors regarding the exercise of the DPO’s tasks
no dismissal or penalty by the controller for the performance of the DPO’s tasks
no conflict of interest with possible other tasks and duties