Not at all atypically, at least in commercial organisations, an image taken (say) for an ID card, under "legitimate interests", is then used more widely. The vast majority of employees don't know (or care) enough to raise it as an issue. ["Our gullible public and how easily fooled ... shame!" - with apologies to Alistair McLean]
> On 19 Jan 2017, at 11:17, Phil Bradshaw <[log in to unmask]> wrote:
>
> I have always been firmly of the view this requires consent.
>
> Sometimes it is not too hard to find a "legitimate interest" (promoting good communications and teamwork may be one) but you would still fail the necessity test.
>
> I also agree any consent cannot be regarded as freely given in the employment context. Any attempt to build the requirement into policy would have Article 8 implications.
>
> On the other hand requiring a photo on ID cards can typically be justified under legitimate interests - including necessity.
>
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