The TTP Code of Conduct GDPR sets out the preconditions for the sharing of (personal) data under the control of (personal) data in the MYOBI Trust Network. In their processor and consent agreements, users of MYOBI can now conveniently refer to this Code of Conduct. To be able to use the Code of Conduct as a code of conduct referred to in the GDPR (Article 40), the Association has made preparations to have the TTP Code of Conduct GDPR approved by the regulator, the Dutch Data Protection Authority (AP).
Advantages of the Code of Conduct
The advantages of an approved Code of Conduct are at least:
- a foundation for data exchange with third countries;
- the supervisors (e.g. AP) consider a member of an approved Code of Conduct as a demonstration of compliance with the GDPR; and
- compliance with the Code of Conduct will moderate a fine to be imposed by a supervisor.
The TTP Code of Conduct GDPR is part of the TTP policy. The precondition is that if a user complies with the TTP Code of Conduct GDPR, he also complies with the TTP policy. In addition to the Association’s activities, MYOBI provides tools exclusively to its users for organising and justifying compliance with the TTP Code of Conduct GDPR. Also, it offers tools to test the DPO’s self-declaration so that other users can rely on this responsibility.
For each user (and therefore each member) this has a great added value: agreements are unambiguous and clear, there is one system of accountability, and this accountability is also interoperable. Chain partners can, therefore, rely on the information contained in the Accountability Seal Register. It avoids unnecessary accounting costs for the company and for the partners.
The Association has a so-called monitoring body. It monitors compliance with the Code of Conduct, provides requested and unsolicited advice and reviews the functioning of the Code of Conduct every two years.
The Association also has a members’ council consisting of a minimum of 5 and a maximum of 10 members. Users of MYOBI can propose candidates for the election of the Members’ Council.