Author: 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.
Karolina Romanowska
Posted on Categories personal data

Remote work vs. personal data processing

The upcoming amendment to the Labour Code on remote work is expected to comprehensively regulate a number of issues and relationships between employer and employee, significantly changing the existing legal landscape for performing work from home. The amendment also touches on issues of processing of personal data. Although work on the bill is still underway, it appears unlikely that the provisions discussed below will change significantly, so it is already worth taking a closer look at them.

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Posted on Categories coronavirus, personal data

Employers will (probably) be able to check their staff’s COVID-19 status

A bill entitled the Act on Specific Solutions Facilitating Business Operations During the COVID-19 Epidemic has been filed with the Sejm. It would allow employers in Poland to demand information from employees about COVID-19 test results, having undergone a COVID-19 infection, or vaccination against COVID-19.

According to the proposal, an employer would be entitled to demand information from an employee or a person in a civil-law relationship (e.g. a contractor) to the effect that the person has obtained a negative COVID-19 test within 48 hours before submission of the information.

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Posted on Categories personal data, whistleblowers

Are you drafting a whistleblowing policy? Don’t forget about personal data

Work is underway on a bill implementing the EU’s Whistleblower Directive (2019/1937). It is not yet clear whether the directive will be implemented into Polish law on time (by 17 December 2021), but many companies are already drafting the necessary documents and organisational procedures.

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Posted on Categories EU law, personal data

Is this the end for personal data transfers to the US?

Since 16 July 2020, companies transferring personal data from the EU to the US, including employees’ personal data, have had a difficult nut to crack. The Court of Justice of the European Union invalidated the decision in the Privacy Shield case, depriving companies of the possibility of basing data transfers to the US on this basis. However, the Court’s judgment (so-called Schrems II) may have serious consequences for companies transferring data to other countries outside the European Economic Area as well.

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