The Article 29 Working Party ("WP29") recently
published an opinion on data
processing at work ("Opinion").
The Opinion restates the position and conclusions in WP29's
2001 Opinion on processing personal data in the employment context
(WP48), and its 2002 WP55 Working Document on the surveillance of
electronic communications in the workplace. However, it addresses
the need for a new assessment of the balance between legitimate
interests of employers and the reasonable privacy expectations of
employees, because of risks posed by advancements in modern
technologies since the other documents were published.
The Opinion is primarily concerned with the Data Protection
Directive 95/46/EC ("DPD"), so employers should continue
to take account of the fundamental principles of the DPD when
processing personal data in an employment context. Technological
developments and new methods of processing have not changed this
position.
