Thank you for everyone's comments. I feel confident that an objection based on breach of the first two principles and arguing that they've passed a theshold for the necessity and balancing tests will at least cause some headaches.

Steve


On Saturday, 7 September 2019, 11:44:32 BST, Steve Cotterill <[log in to unmask]> wrote:


Hi all,

I would be grateful for any advice on the below:

My employer (Local Authority) has decided that they will attach a photo of my on all of my emails. I would be grateful if you could provide some advice to me as to whether they have met the 'legitimate interest' exemption.

They have stated that the exemption they are using is the 'legitimate interests' exemption because having my photo on all emails will "improve collaboration between employees". They intend to share the image with partner ogranisations and have reserved the right to share it with 'trusted partner organisations".

They have already decided that any objection from data subjects is likely to fail.

The reason they collected the original image was to put on a security card, not to attach to emails that I may, receive send or be copied into.

I do not believe that having my image on the email for the reason stated ("improve collaboration between employees") is valid and therefore fails the legitimate interestes test (as it a nice to have but nothing else and there is no proof that this processing will meet the desired objective).

I would be grateful for any advice on reasoning I can object to this (You may think I am being unnecessarily obstructive on this but they have not enagegd with employees on this and only provided a 'lawful basis for processing' after people raised complaints).

Do they have a legitimate interest? Can I also invoke HRA 1998 - right to privacy?

Apologises for the long email. Any help gratefully received.

Steve 



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