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White paper for Data protection officers

Die Aufgabe, für die niemand Sie gebucht hat.

Deutschsprachiges Papier für Datenschutzbeauftragte.

The problem this is about

The question rarely arrives as an assignment. It arrives as a follow-up at the end of a call.

Training is the smallest part of the work, and the only part the workforce ever sees.

What is inside

  • What Arts. 39, 32 and 5(2) require, and what is explicitly absent (an interval)
  • The three stopgaps compared, and what each one costs
  • The six fields of a defensible training record
  • Co-determination: §§ 87(1)(6) and 98 BetrVG
  • Conflict of interest under Art. 38(6): addressed rather than omitted

For external data protection officers with several clients, and for internal DPOs.

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  • 11 pages
  • PDF
  • As of August 2026

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All papers provide general information and are not legal advice.

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