Personal data in the workplace.
WHAT EMPLOYERS HOLD
Application materials Identity and right-to-work documents Contracts and pay records Performance records Disciplinary records Health information, sometimes Emergency contacts
WHAT LAWFUL BASIS USUALLY APPLIES
Contract, for employment administration Legal obligation, for tax and statutory records Legitimate interests, for some management activity
WHY CONSENT IS USUALLY WRONG HERE
The power imbalance means it is rarely freely given.
WHAT TO TELL STAFF
What you hold, why, and for how long.
WHERE
An employee privacy notice, separate from the customer one.
WHAT RECRUITMENT REQUIRES
Telling candidates what happens to their data Deleting unsuccessful applications after a defined period
WHAT PEOPLE FORGET
Applications accumulating indefinitely in mailboxes.
WHAT MONITORING REQUIRES
A lawful basis Transparency Proportionality
WHAT COVERT MONITORING REQUIRES
Exceptional justification, and usually advice.
WHAT TO BE CAREFUL WITH
Reading staff email Tracking location Monitoring productivity
WHAT TO DO BEFORE ANY OF IT
Assess necessity, and tell people.
WHAT HEALTH DATA REQUIRES
Restricted access, and a clear basis.
WHAT TO DO WHEN SOMEONE LEAVES
Apply the retention schedule, and remove access promptly.
