Recent position of the Personal Data Protection Office (PDPO) on the Workplace SocialBenefits Fund (the Fund)
PDPO maintained its position on the principles of data processing for the purposes of using services and benefits financed from the Fund.
Pursuant to the Act on the Fund services, benefits and subsidies depend on the life, family and material situation of person entitled to use the Fund.
This means that the employer needs to know the financial situation of both the employee and the members of their family with whom they run a joint household, and thus process their data in this respect.
In the opinion of PDPO, the processing of personal data of an employee and their family members should be carried out in accordance with the principles of GDPR, such as: data minimization, limited access, legitimate purposes.
The employer may only request access to certain documents, without the right to collect them. As an example, the spouse’s income tax statement was mentioned.
Employers running the Fund must carry out annual reviews of their records to verify that they process only data necessary to meet the objectives of social benefits.
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Link (text in Polish): https://lnkd.in/dHv62wj