The Article 29 Working Party, which is a body made up of a representative from the data protection authority of each EU Member State, the European Data Protection Supervisor and the European Commission, issued its Opinion 2/2017 on data processing at work. This Opinion complements the previous Article 29 Working Party’s Opinion 8/2001 on the processing of personal data in the employment context, and the 2002 Working Document on the surveillance of electronic communications in the workplace.

The local regulator – the Slovak Authority for Personal Data Protection – typically relies on the guidance developed by the Working Party.

The new Opinion may be helpful to Slovak employers and may guide their data processing operations.

The new Opinion deals with various practical questions such as processing operations during the recruitment process; processing operations resulting from in-employment screening; processing operations resulting from monitoring ICT usage at the workplace and outside the workplace; processing operations relating to time and attendance; processing operations using video monitoring systems; processing operations involving vehicles used by employees; processing operations involving disclosure of employee data to third parties; and processing operations involving international transfers of HR and other employee data.

The Opinion also addresses matters concerning employees’ fundamental rights; employee consent; the principles of transparency, proportionality and data minimization; and cloud services, online applications and international transfers.