SKW Schwarz advises VDDW on the development, design and approval of a code of conduct

SKW Schwarz advised the VDDW (Association of the German Water and Heat Meter Industry) on the design and negotiation of a code of conduct for the handling of personal data by the metering industry for cold/hot water and thermal energy. The Code of Conduct was developed in accordance with the principles of the GDPR, in particular Articles 40 and 41 GDPR, in close cooperation with the LDI NRW (State Commissioner for Data Protection and Freedom of Information North Rhine-Westphalia). The Code of Conduct was approved after consultation with the German Data Protection Conference (DSK) on 25 June 2025.

The aim of the Code of Conduct is to counteract legal uncertainty in the (application) area of data protection for measuring device manufacturers. The rules of conduct specify the requirements for remotely readable measuring devices for cold/hot water and thermal energy in the main section and in the appendix ‘Technical Requirements’. The added value of the Code of Conduct is that it transparently presents the processing of data via remotely readable measuring devices, limits the scope of data in accordance with the various purposes and describes possible storage periods.

The VDDW has represented the leading manufacturers of water and heat meters in Germany since 1953. It formulates and represents all the common technical and economic interests of its member companies vis-à-vis politicians, ministries, relevant federal and state authorities (e.g. calibration supervisory authorities), legislative bodies and comparable international authorities, standardisation organisations and the public.

Click here for the LDI NRW press release >>

Advisors to VDDW – Verband der Deutschen Wasser- und Wärmezählerindustrie e.V. (Association of the German Water and Heat Meter Industry): 
SKW Schwarz, Frankfurt: Dr Oliver Hornung (lead), Franziska Ladiges, Dr Wulf Kamlah (of counsel); associate: Marius Drabiniok (all IT & Digital Business)