Raine v JD Wetherspoon: A Wake-Up Call On Oral Disclosures And Data Protection

The High Court's decision inRaine v JD Wetherspoonoffers a reminder to employers on the importance of safeguarding employee data, especially in high-risk situations. The case clarifies how oral disclosures of recorded data can still constitute "processing" under theUK GDPR. For HR and privacy professionals, this judgment underscores the need for robust training, clear policies, and practical implementation of data protection protocols.

Background

The Claimant, a former JD Wetherspoon ("Wetherspoons") employee, had provided her mother's mobile number as her emergency contact while employed at Wetherspoons. These details were stored in the Claimant's personal file, which was marked "Strictly Private and Confidential" and stored securely. In 2018, the Claimant began to suffer serious abuse and harassment from her partner at the time. She informed a manager about this on three separate occasions during formal meetings, and raised that she feared further contact. The