Hi,

 

I think the two legal basis you would be look at are Consent or Legitimate Interests.

 

The problem with consent is its an employer/employee relationship so there is an imbalance of power.

“Public authorities, employers and other organisations in a position of power over individuals should avoid relying on consent unless they are confident they can demonstrate it is freely given: ICO”

I think given the nature of the personal data is limited, and you will/should have a contract with the new data processor. You could look at relying on legitimate interests.

To do this you would need to:

• Do a Legitimate Interests Assessment, alongside a DPIA
• Look at an opt-out communication before the sharing staff names
• Ensure the third-party issues an opt-out with every email to an employee

Kind Regards

 

Jess Pembroke

Head of Data Protection
Naomi Korn Associates
www.naomikorn.com

 

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Hi all

 

I wonder if anyone can provide me with a clear answer on the following – apologies if it’s a daft question.

 

As a College we are about to change our provider for company perks having previously used Sodexo.  When we set up with Sodexo it was all voluntary and staff signed up if they wished to do so.  The new company have requested a spreadsheet of all staff names and work email addresses – can this be done without the consent of staff? 

 

Thank you in advance for any pearls of wisdom.

 

Sarah

 

Sarah Adams
Clerk to the Corporation | Lincoln College Group
Tel: 01522 876216
Email: [log in to unmask]

 

 

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