We had a very similar discussion when changing HR systems, and sought the advice of the ICO. They were uncharacteristically helpful over the phone and took a similar view to Hellen - it is clear that data regarding genders other than those assigned at birth deserve further protection and that at a pRead more
We had a very similar discussion when changing HR systems, and sought the advice of the ICO. They were uncharacteristically helpful over the phone and took a similar view to Hellen – it is clear that data regarding genders other than those assigned at birth deserve further protection and that at a pinch, they might consider that data to fall within the sex-life/orientation category.
Not perfect, I know, but does seem odd that it wasn’t included given the issue’s prevalence and potential for harm.
Stonewall also produced some good guidance on this, especially regarding using substantial public interest as an Art. 9 condition for processing. If anyone’s interested, I can email them a copy.
Thanks Hellen, I'd not actually seen that page. One thing that bugs me about the ICO's website is it rarely pinpoints what it's referring to in the legislation. E.g. "The EU Exit Regulations provide provisional arrangements so that UK adequacy regulations include the EEA and all countries, territoriRead more
Thanks Hellen, I’d not actually seen that page.
One thing that bugs me about the ICO’s website is it rarely pinpoints what it’s referring to in the legislation. E.g. “The EU Exit Regulations provide provisional arrangements so that UK adequacy regulations include the EEA and all countries, territories and international organisations covered by European Commission adequacy decisions valid as at 31 December 2020” – but then doesn’t direct you to where that is.
You'd obviously need to have a look at LinkedIn's Ts&Cs, but could you perhaps set up a generic account used solely for this purpose? I guess it depends on how many people the organisation has fulfilling this role, as it's probably not advisable to have multiple users sharing one generic accountRead more
You’d obviously need to have a look at LinkedIn’s Ts&Cs, but could you perhaps set up a generic account used solely for this purpose? I guess it depends on how many people the organisation has fulfilling this role, as it’s probably not advisable to have multiple users sharing one generic account.
Gender and Special Category Data
Henry
We had a very similar discussion when changing HR systems, and sought the advice of the ICO. They were uncharacteristically helpful over the phone and took a similar view to Hellen - it is clear that data regarding genders other than those assigned at birth deserve further protection and that at a pRead more
We had a very similar discussion when changing HR systems, and sought the advice of the ICO. They were uncharacteristically helpful over the phone and took a similar view to Hellen – it is clear that data regarding genders other than those assigned at birth deserve further protection and that at a pinch, they might consider that data to fall within the sex-life/orientation category.
See lessNot perfect, I know, but does seem odd that it wasn’t included given the issue’s prevalence and potential for harm.
Stonewall also produced some good guidance on this, especially regarding using substantial public interest as an Art. 9 condition for processing. If anyone’s interested, I can email them a copy.
UK Adequacy Decision FOR the EU
Henry
Thanks Hellen, I'd not actually seen that page. One thing that bugs me about the ICO's website is it rarely pinpoints what it's referring to in the legislation. E.g. "The EU Exit Regulations provide provisional arrangements so that UK adequacy regulations include the EEA and all countries, territoriRead more
Thanks Hellen, I’d not actually seen that page.
One thing that bugs me about the ICO’s website is it rarely pinpoints what it’s referring to in the legislation. E.g. “The EU Exit Regulations provide provisional arrangements so that UK adequacy regulations include the EEA and all countries, territories and international organisations covered by European Commission adequacy decisions valid as at 31 December 2020” – but then doesn’t direct you to where that is.
See lessUK Adequacy Decision FOR the EU
Henry
Thanks Dean - I had a feeling it was lurking somewhere like that...
Thanks Dean – I had a feeling it was lurking somewhere like that…
See lessEmployees accessing information using personal LinkedIn accounts.
Henry
You'd obviously need to have a look at LinkedIn's Ts&Cs, but could you perhaps set up a generic account used solely for this purpose? I guess it depends on how many people the organisation has fulfilling this role, as it's probably not advisable to have multiple users sharing one generic accountRead more
You’d obviously need to have a look at LinkedIn’s Ts&Cs, but could you perhaps set up a generic account used solely for this purpose? I guess it depends on how many people the organisation has fulfilling this role, as it’s probably not advisable to have multiple users sharing one generic account.
See less