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CRodica

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  1. Asked: August 16, 2022In: GDPR, Privacy Management

    Overseas data subjects

    CRodica

    CRodica

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    CRodica Rising star contributor
    Added an answer on August 26, 2022 at 9:39 pm

    I would say you take the GDPR as the gold standard as other laws take most principles from it. However, you will need to do a gap assessment for other laws where there are divergences and implement those in addition to GDPR’s requirements.

    I would say you take the GDPR as the gold standard as other laws take most principles from it. However, you will need to do a gap assessment for other laws where there are divergences and implement those in addition to GDPR’s requirements.

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  2. Asked: July 13, 2022In: GDPR

    providing personal contact details

    CRodica

    CRodica

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    CRodica Rising star contributor
    Added an answer on July 26, 2022 at 12:00 am

    I would say you need to assess the necessity of getting the personal contact details of all those employees. For senior members, whose involvement is necessary in case of an emergency, I would say it meets such requirement, and legitimate interest can be used. however, it is the same for the rest ofRead more

    I would say you need to assess the necessity of getting the personal contact details of all those employees. For senior members, whose involvement is necessary in case of an emergency, I would say it meets such requirement, and legitimate interest can be used. however, it is the same for the rest of the employees? I’d depends on the purpose, what kind of emergencies? Based on this, the relevant lawful basis should be used, legitimate interest or consent. But you also should consider whether the consent would actually meet the requirements of freely given in an employment context, and they can withdraw it at any time without consequences. If this leads to the idea that actually the contact details are necessary, then probably legitimate interest is the right option. Or is it necessary at all?

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  3. Asked: July 18, 2022In: GDPR, Privacy Management

    Access to emails

    CRodica

    CRodica

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    CRodica Rising star contributor
    Added an answer on July 25, 2022 at 11:48 pm

    You can see some case law on monitoring employees’ correspondence here https://www.echr.coe.int/Documents/FS_Workplace_surveillance_ENG.pdf Basically, the interference should be necessary and proportionate to the purpose, hence the unlimited access is unlikely to meet these requirements

    You can see some case law on monitoring employees’ correspondence here https://www.echr.coe.int/Documents/FS_Workplace_surveillance_ENG.pdf
    Basically, the interference should be necessary and proportionate to the purpose, hence the unlimited access is unlikely to meet these requirements

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  4. Asked: May 11, 2022In: GDPR, Privacy Management

    It’s that dreaded time! I need to put together some FUN Data Protection training for Staff. Anyone have some great clips, quizzes, etc that they wouldn’t mind sharing!

    CRodica

    CRodica

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    Added an answer on June 14, 2022 at 11:29 pm

    If this is for a certain team, as a suggestion is to understand what the team’s priorities are, what plans and activities they do so that the training relates to their work. This sparks interest and questions

    If this is for a certain team, as a suggestion is to understand what the team’s priorities are, what plans and activities they do so that the training relates to their work. This sparks interest and questions

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  5. Asked: June 13, 2022In: GDPR

    CCTV warning signs

    CRodica

    CRodica

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    CRodica Rising star contributor
    Added an answer on June 14, 2022 at 11:21 pm

    There are no rules on how many signs should be. The requirement is to provide clear notice to people before collecting the data. So it would need to be visible, clear to understand that by entering the specific office/location, the space is monitored. This ideally should be prior to entering, and haRead more

    There are no rules on how many signs should be. The requirement is to provide clear notice to people before collecting the data. So it would need to be visible, clear to understand that by entering the specific office/location, the space is monitored. This ideally should be prior to entering, and have some contact information to the DPO or office responsible for data protection matters for any questions.

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  6. Asked: June 14, 2022In: GDPR

    What is a data processors legal basis for using data related to app usage?

    CRodica

    CRodica

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    CRodica Rising star contributor
    Added an answer on June 14, 2022 at 11:12 pm

    If it is for processor’s own interest who is taking on its own the decision to proceed with this analysis, then he is no longer a processor, but controller. Most likely it would rely on legitimate interest as no other grounds would be applicable. But this would require also to perform an LegitimateRead more

    If it is for processor’s own interest who is taking on its own the decision to proceed with this analysis, then he is no longer a processor, but controller. Most likely it would rely on legitimate interest as no other grounds would be applicable. But this would require also to perform an Legitimate Interest Assessment (LIA).
    If however, the activity is performed at the instructions of another company, then a data processor would not need a legal basis, but do so based on the contract with that company and based on its instructions.

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