ICO briefly touches upon the NOK/ Emergency Contact issue at 2.1.3 of the supplementary guidance to Employment Code.
As to condition for processing currently we clearly have "legitimate interest" and there would really be no need to seek consent.
Under GDPR this may be an issue for a public authority. But are we sure it is not available. The restriction in GDPR relates to "processing
carried out by public authorities in the performance of their tasks. " Is employment one of those tasks?
By analogy with other areas such as Re-Use of information, RIPA, etc. I am not sure it is.
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