Presume that we are talking commercial sector here?
What sector, and what do employment T&Cs say? Is the individual 'public facing' or 'back office'? How senior are they? Key Q: would it be reasonable for them to expect that their identity and a 'face to name' would be of interest to the organisation's customers, partners, suppliers etc?
ICO guidance on disclosure of employee details vs S40 and S41 of the Freedom of Information Act (2000) might be useful here - https://ico.org.uk/media/for-organisations/documents/1213/personal-information-section-40-and-regulation-13-foia-and-eir-guidance.pdf and https://ico.org.uk/media/1432163/information-provided-in-confidence-section-41.pdf
In brief, disclosure of personal information about public sector employees can be legitimately exempted from provision under FOI if they have no strategic or financial power/responsibility and no, or very limited dealings with the public.
Finally, still importantly, need to consider safety - employee may be at risk from publication e.g. if escaping domestic violence.
Hope this helps
Sandre
Sandre Jones
Information Governance Lead
Nottingham CityCare Partnership
Rm 44 New Brook House
385 Alfreton Road
Nottingham
NG7 5LR
Tel: 0115 883 9534 EXT 39534
Mob - preferred: 07545 422312
Nottingham CityCare Partnership CIC is registered as a company limited by guarantee.
Company Registration Number: 07548602
Registered address: 1 Standard Court, Park Row, Nottingham, NG1 6GN
-----Original Message-----
From: Ian Griffiths [mailto:[log in to unmask]]
Sent: 25 September 2015 23:01
Subject: Face on a website
Quick Friday evening one, need some reasons why an employee should be allowed to opt out of having their face on the company web site.
Sure there are DP reasons but the company seem not to agree and without specific guidance, they seem unwilling to move.
Ian
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