Employers should review whether additional personal data collected during the pandemic is still required
Employers will welcome new guidance from the Information Commissioner's Office (ICO), designed to help them continue to comply with data protection laws now that Covid-19 restrictions have been removed.
Under the guidance, employers should review whether additional personal data collected from and about employees in order to keep them safe during the pandemic is still required, or if the reasons for collecting it can be satisfied in some other way. If information is not required, it should be securely disposed of.
Data about vaccination status is ‘health data’ and special rules apply, so employers should consider whether the primary reason for processing that data is still fair, relevant and necessary, and complies with the special rules. Where large amounts of such data are being processed, a data protection impact assessment is required.
Employers can download the new guidance from the ICO website to check they are complying, to meet their data protection obligations to staff.
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