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Saturday, October 10, 2026

Data Protection in employment relationships An overview of applicable laws in SE Europe - Lexology

The employment field is one of the main sectors where data protection issues arise. The special circumstances of the employer – employee relationship, particularly the dependence and the imbalance of power between the parties involved need to be taken into account when implementing the general data protection law principles. We provide herein below an outline of the main law and regulatory positions taken across SE European jurisdictions in relation to data protection in employment relationships.

Greece

Greek Law 4624/2019, implementing certain GDPR provisions avails of the option provided by the GDPR (article 88 par. 1) to regulate in more detail specific processing cases, such as the processing of data in the context of employment. Art. 27 thereof, also taking into account the labor law principle imposing on the employer a general obligation to protect its employees, provides that employers may process the personal data of (existing or previous) employees and candidates, provided that it is absolutely necessary: (a) in order to decide whether to conclude an employment agreement; or (b) in order to execute such employment agreement after its conclusion.

Special categories of personal data may be processed only if necessary to exercise rights/ fulfil obligations deriving from labor law, social security and social protection law, and provided the data subject’s legitimate rights concerning the processing are not overriding. Consent may only exceptionally serve as an...



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