❗️Use of the e-mail address of a former employee – new position of the Polish Personal Data Protection Office (UODO)
➡️ if the employer still has an active e-mail address of the former employee which was assigned to him/her in the course of his/her duties, he/she remains the controller of this data
➡️ if the former employee was responsible for contact with customers, the employer may still use this e-mail address, eg by means of an automatic response addressed to customers or contractors
➡️ if the message includes information that the employee is no longer employed and an indication of the e-mail address at which the current representatives of the entity can be contacted, then, this type of action can be treated as a legitimate interest of the data controller
➡️ the former employee’s details may only be used by the employer only if the customer makes an attempt to contact him/her and only to indicate the current contact details
➡️ active use of the e-mail address (eg the acquisition of new customers) is unacceptable
Link: https://lnkd.in/dXWVPQZ
