On February 9, 2023, the Court of Justice of the EU (“CJEU”) released two separate rulings on the dismissal of data protection officers (“DPOs”) under the German Federal Data Protection Law (“German DPL”) (C-453/21 and C-560/21). The main question in both cases was whether Section 6(4) of the German DPL which permits the dismissal of a DPO with “just cause” is compatible with the GDPR. In short, the CJEU (i) found that the provision was compatible with the GDPR because EU member states can use “just cause” as a threshold for dismissal as long as this does not undermine the objectives set for DPOs under the GDPR, and (ii) clarified the criteria EU member states should take into account to determine whether there is a conflict of interest.Continue Reading Court of Justice of the EU Clarifies Rules on Data Protection Officers’ Dismissal and Conflicts of Interest