How do you demonstrate DPO independence in practice?
By showing the DPO can advise, challenge, and escalate without interference.
Why this matters
Independence is a core regulatory expectation.
Indicators of independence
- Direct access to senior leadership
- Freedom from operational conflicts
- Ability to raise concerns formally
How independence is evidenced
- Governance documentation
- Reporting lines
- Records of challenge and escalation
What good looks like
A DPO whose advice is visible, considered, and respected.