Steve,
Phil, is right, it would fail on the necessity test and certainly on the balancing test ... if it even got that far.
I would ask to see the Legitimate Interests Assessment as they either haven't done one or have but done it badly.
If they are planning to deny any right to object, I'd ask them what the "compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject" is.
Regards
Matt
Matthew Stephenson
Risk and Compliance Manager and Data Protection Officer
Legal and Governance
University of Bradford
+44 (0) 1274 233021
www.bradford.ac.uk
-----Original Message-----
From: This list is for those interested in Data Protection issues <[log in to unmask]> On Behalf Of Phil Bradshaw
Sent: 09 September 2019 09:29
To: [log in to unmask]
Subject: Re: [data-protection] Phtot on Work Email
Agree 100% with Tim. No basis for repurposing a security photo which employee has no choice but to supply other than clear consent with no pressure to comply.
On LI I disagree slightly. I am sure an employer has an LI in improving collaboration.
But IMO fails utterly on the necessity point. What evidence do they have that it works, other than a feeling that it is a cool thing to do? What evidence do they have that then purpose cannot be achieved by other means? And even if you scrape over that very high hurdle any objection (as Tim says) will have to be respected.
On an irrelevant lighter note some of the photos I see might make me less inclined to collaborate in case it makes me more likely to have to meet them …
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