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Greece: HDPA issues opinion on sensitive data in response to ASEP request
The Hellenic Data Protection Authority ('HDPA') issued, on 31 March 2020, its opinion ('the Opinion') on the sharing and processing of sensitive personal data on the Council of Civil Personnel Selection's ('ASEP') webpage, as provided under Article 36 of the General Data Protection Regulation (Regulation (EU) 2016/679) ('GDPR'), and as requested by ASEP. In particular, the Opinion states that ASEP requested the HDPA's opinion because the posting of ranking tables including personal data of candidates and appointees is likely to result in a high risk to the rights and freedoms of individuals.
In addition, the Opinion highlights that the HDPA, having taken into consideration Articles 9(2)(g), 35, and 36 of the GDPR, decided that in order for such sharing to be legitimate and in accordance with the GDPR, ASEP needs to, among other things, provide each individual in the ranking tables with a unique account and delete candidates' identification data such as name, surname, and ID. Finally, the Opinion states that the retention time of personal data should be limited to what is absolutely necessary and in accordance with the original purpose of the processing.
You can read the Opinion, only available in Greek, here.
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