GDPR codes of conduct & certification schemes
The approved organisational instruments under the GDPR — certification schemes under Article 42 and codes of conduct under Article 40 — for the UK (ICO-approved) and the EU (EDPB-adopted). These are schemes an organisation's processing can be certified against or a code it can sign up to; they are not individual qualifications. UK-first, with a link to each official register.
Article 40 vs Article 42 — the difference in a nutshell
Both are accountability tools that let an organisation demonstrate GDPR compliance, and both can act as a safeguard for restricted international transfers — but they work differently.
| Certification schemes — Art. 42 | Codes of conduct — Art. 40 | |
|---|---|---|
| What it is | Criteria against which an organisation's specific processing is certified. | A sector code of good practice that member organisations commit to follow. |
| Who approves | Supervisory authority (or EDPB, for an EU-wide seal) approves the criteria. | Supervisory authority approves the code. |
| Who checks compliance | An accredited certification body issues certification (valid up to 3 years). | An accredited monitoring body (Art. 41) oversees members. |
| Transfer safeguard | Can be a transfer tool under Art. 46(2)(f). | Can be a transfer tool under Art. 46(2)(e). |
UK and EU are separate regimes: UK-approved instruments are approved by the ICO under UK GDPR; EU-approved ones by an EU supervisory authority or the EDPB. An approval under one regime does not automatically carry across to the other.
- Schemes — UK (ICO)
- Schemes — EU (EDPB)
- Codes — UK (ICO)
- Codes — EU
- Statutory codes — other jurisdictions
Certification schemes (Art. 42) — UK, ICO-approved
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ADISA ICT Asset Recovery Certification 8.0
ICO-approved criteria: Standard 8.0 v4.0 Part 1 (ICO-CSC/003:2) and Part 2 Criteria (ICO-CSC/004:3), approved 18 March 2026 to reflect the Data (Use and Access) Act 2025 · originally approved 19 July 2021 (v3.1/v3.2, ICO-CSC/003:1 and /004:2, valid until certified organisations have transitioned) · owner and UKAS-accredited certification body: ADISA Certification Ltd (UKAS 23831)What it covers: Data protection requirements for processors and sub-processors providing data sanitisation services — permanently removing information from IT hardware so it can be securely disposed of or reused.
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Age Appropriate Design Certification Scheme (AADCS)
ICO-approved criteria (ICO-CSC/002) · body: Age Check Certification Scheme LtdWhat it covers: Children's online privacy and the design of information society services, aligned to the ICO's Children's Code (Age Appropriate Design Code).
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Age Check Certification Scheme (ACCS)
ICO-approved criteria (ICO-CSC/001) · the first ICO-approved UK GDPR criteriaWhat it covers: Age assurance and age verification — the first set of criteria the ICO approved under UK GDPR.
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Legal Services Operational Privacy Certification Scheme (LOCS:23)
ICO-approved criteria ICO-CSC/006 · approved 1 February 2024 · scheme owner: 224Protect Ltd (previously trading as 2Twenty4 Consulting Ltd) · certification body: ADISA Certification Ltd (UKAS accreditation 23831)What it covers: Data protection in the legal-services sector — law firms, solicitors, barristers’ chambers and other providers, as controllers and processors, for personal data held in the client file. Criteria document: LOCS:23 Standard v12.3.
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UK GDPR Compliance Certification Scheme for the Provision of Training and Qualifications Services
ICO-approved criteria (ICO-CSC/005)What it covers: The handling of learner and candidate data by organisations providing training and qualifications services.
Certification schemes (Art. 42) — EU, EDPB-adopted
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Europrivacy — European Data Protection Seal
Managed by the European Centre for Certification and Privacy (ECCP), Luxembourg · EUWhat it covers: A general-purpose GDPR certification scheme and the first to be adopted by the EDPB as the official European Data Protection Seal (EDPB Opinion 28/2022). In April 2026 the EDPB issued further opinions updating the scheme's criteria and extending its scope — including to non-EEA organisations caught by Art. 3(2) — and recognising it as a tool for restricted international transfers under Articles 42 and 46.
Note: The individual Europrivacy Implementer and Auditor credentials sit in our Certifications directory.
Codes of conduct (Art. 40) — UK, ICO-approved
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ABI UK GDPR Code of Conduct for Investigative & Litigation Support Services
ICO-approved code (ICO-CC/001) · owner: Association of British Investigators · approved 15 October 2024What it covers: The first ICO-approved UK GDPR code of conduct. It helps members providing investigative and litigation-support services demonstrate compliance — covering controller/processor roles, DPIAs, lawful basis, legitimate-interests assessments and consent to share when tracing and locating individuals.
Codes of conduct (Art. 40) — EU, transnational
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EU Cloud Code of Conduct (EU Cloud CoC)
Approved by the Belgian DPA (20 May 2021) · monitoring body: SCOPE Europe · EUWhat it covers: An Article 40 code for cloud service providers acting as processors under Article 28, covering the full cloud stack (IaaS, PaaS and SaaS).
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CISPE Data Protection Code of Conduct
Approved by the CNIL (France) · EUWhat it covers: An Article 40 code for cloud infrastructure (IaaS) providers, developed by CISPE and approved by the French supervisory authority.
Statutory codes of practice — other jurisdictions
Codes issued by a regulator with the force of law under its own statute — not Article 40 industry codes. Listed where they offer a useful comparator for UK practice.
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Biometric Processing Privacy Code 2025 (BPPC)
Issued by the Privacy Commissioner under the Privacy Act 2020 · New Zealand · issued 21 July 2025, in force 3 November 2025; transition for existing users ended 3 August 2026; Amendment No 1 (March 2026) in force 1 May 2026What it covers: Privacy rules for agencies collecting and using biometric information in biometric processing (facial recognition and similar) — a proportionality test before collection, transparency duties, and limits on use such as detecting health information without specific authorisation. Six OPC factsheets and full guidance accompany it.
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