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Polish Data Protection Authority reaffirms personal data rules


Polish Data Protection Authority (‘UODO’) reaffirms personal data rules when recruiting.

The Polish Data Protection Authority has issued a statement highlighting that employers should not :

  • obtain data that is not needed for the purposes of recruitment
  • rely on consent for the processing (unless the applicant agrees to the retention of their data for the purposes of future recruitment for a specified period)
  • obtain personal data which is unrelated to the purpose of hiring, such as a photo, or information on pending and unfinished criminal proceedings.
  • contact previous employers who provided references to obtain additional information about the applicant


It is surprising and disappointing that this regulator needed to emphasise to employers, more than two years after the GDPR came into effect, that the consent of job applicants is not an appropriate lawful basis to process their personal information. Unfortunately, it is still often the case that as part of a recruitment process, more information is collected than is needed and that the CVs etc of unsuccessful applicants are kept, usually without their knowledge, on the basis that ‘something else may come up’.

If your organisation is looking to comply with the requirements of the GDPR then take a look at how our CSaaS and DPaaS solutions can help.

Appointing NormCyber as our virtual DPO has given Ferrero the best of both worlds – access to data protection experts who understand what we stand for as a business, without the hefty overheads usually associated with appointing an in-house DPO.

Harpreet Thandi
Regional Counsel, UK & Ireland, Ferrero

We were looking for a virtual DPO service that offered all of the benefits of a fully qualified data protection lawyer, without the overheads of an in-house hire. The DPaaS solution from norm. has been invaluable in helping us to ensure we respect the integrity of our customers’ personal information, while using it to continue to deliver differentiated products and services which support our growing customer base.

Mike Whitfield, Compliance Manager

CSaaS allows me to step away from multi-vendor management as the Security Operations Centre coordinates all of the technology for me.

David Vincent, CTO

We were in the market for an independent Data Protection Officer service that was well versed with both UK and EU regulators. We’re thrilled to have acquired this service knowing that an expert is available 24/7.

Suzanne McCabe, Head of Project Management
James Hambro & Partners

Norm’s penetration testing layer, along with the suite of CSaaS modules has enabled MA to exceed all its audit requirements for its major clients.

Rob Elisha, ICT and CRM Manager
Montreal Associates

The speed of your Data Protection Officer’s response was very impressive – it was far quicker than I would have expected even from an in-house DPO

Will Blake, Director of Technology and Analytics
CRU Group