Interesting comment. What are you suggesting? That the DPO should never be an employee or that it's not possible to completely remove a conflict of interest?
Not the most practical of viewpoints to adopt, I have to say....
>-----Original Message-----
>From: This list is for those interested in Data Protection issues [mailto:data-
>[log in to unmask]] On Behalf Of Harvey Andrew (Western Sussex
>Hospitals)
>Sent: 11 July 2017 11:22
>To: [log in to unmask]
>Subject: Re: [data-protection] DPO - where does it sit?
>
>By being an employee there is an inherent conflict of interest, always.
>
>Kind regards,
>Andrew.
>
>
>Andrew Harvey AMIRMS
>Head of Information Governance
>GDPR Data Protection Officer
>Chair, Sussex-Wide Information Governance Group Western Sussex Hospitals
>NHS Foundation Trust Worthing Hospital, Lyndhurst Road, Worthing, BN11
>2DH Tel 01903 205111 x84508 Mob 07900 736922 Email
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>-----Original Message-----
>From: This list is for those interested in Data Protection issues [mailto:data-
>[log in to unmask]] On Behalf Of Bill Dunn
>Sent: 11 July 2017 11:20
>To: [log in to unmask]
>Subject: Re: [data-protection] DPO - where does it sit?
>
>Hi,
>
>We have not appointed a DPO yet under the GDPR - we are mindful of this
>case from Germany - https://globalcompliancenews.com/germany-data-
>protection-officer-conflict-of-interest-20161121/ and presume that the GDPR
>will be interpreted in much the same way.
>
>How are you dealing with ensuring that the DPO has no "conflict of interests"?
>Are we over reacting?
>
>Bill
>
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