In its paper published on 30 June 2020, the Data Protection Authority (“DPA”) expressed the view that the data of management board members representing a legal person are protected by the GDPR as the data of natural persons who are identifiable by using data disclosed in the National Court Register.
Continue reading “Is there an obligation to inform management board members?”
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.
Continue reading “When will employers use employees’ fingerprints?”
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.
Continue reading “COVID-19 and GDPR, can an employer ask where you have travelled?” 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).
Continue reading “Annual review of personal data processed for the purposes of the Workplace Social Benefits Fund”