Karolina Romanowska
Karolina Romanowska, adwokat, handles issues of data protection and employment law. She has experience adjusting HR documentation to the requirements of the General Data Protection Regulation for a number of leading companies from the sectors of logistics, food, sport, and financial services. She advises HR departments in negotiation of contracts involving processing of personal data. She also participates in corporate due diligence.
According to the
Personal Data Protection Authority (“DPA”), employers may not process
employees' biometric data to record working time. However, this does not mean
that employers may not use such data for other purposes.
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The dangers caused by COVID-19 result in many employers unilaterally introducing measures to protect their employees from falling ill with the virus. For example, they measure their temperature before they enter the workplace or ask them to complete declarations stating where (in which country) and with whom they spent their holidays. As a result, a number of personal data is collected, including special categories of personal data (concerning health). An extraordinary situation, however, does not entitle employers to take completely arbitrary action.
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Almost two years have passed since the GDPR came into being and yet many employers are still unaware that special regulations were introduced to the Workplace Social Benefits Fund Act which impose on them numerous obligations related to the processing of personal data for the purposes of granting benefits from the Workplace Social Benefits Fund (Zakładowy Fundusz Świadczeń Socjalnych, ZFŚS).
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