So as to keep WAPI members up to date with the ICO’s possible introduction of a GDPR Code of Conduct for Private Investigators, we have carried out research and also made a formal approach to the ICO, the result of which is we are able to advise members as follows:

  1. A UK Code of Conduct should be available to potential Code Members within the sector and not restricted to ‘members only’ of a trade association/body.


  1. A trade association or body can develop a Code of Conduct in their sector as long as they can demonstrate they:


  1. a) are able to speak on the behalf of a group of organisations;
  2. b) have the necessary experience within their sector; and
  3. c) understand the needs of the organisations.


  1. Construction and membership of a Code is however entirely voluntary and is in no way a requirement of the ICO or a requirement of UK Data Protection legislation.


The above requirements are a general overview of a lengthy document supplied by the ICO to WAPI via our legal representatives.

In conclusion we are of the opinion that the process and requirements expected by the ICO are so rigorous, that in the current climate the circumstances of our industry are such, no association will be granted the status of a GDPR Code of Conduct for the sector unless a collaboration between associations/institutes is in place.

Gary Murray, F.Inst. Pa

Fellow of the Institute of Paralegals

WAPI GC Member – GDPR and Data Protection