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#12130 - 04/04/18 02:26 PM GDPR  
Joined: Feb 2008
Posts: 11
whi5tler Offline
newbie
whi5tler  Offline
newbie

Joined: Feb 2008
Posts: 11
Prague, Czech Republic
Hi everybody,

I was wondering if anybody had any information pertaining to GDPR for HCM and particularly 'The Right to be Forgotten'? We have a customer who has asked this question and not being able to find anything on Google or MoS I thought I would ask here if anybody has any experience with any solutions being applied. My first thought is that a CEMLI would have to be created to solve this?

Any help appreciated.

#12131 - 05/04/18 05:31 AM Re: GDPR [Re: whi5tler]  
Joined: Mar 2005
Posts: 1,287
delboy Offline
The Grand Daddy
delboy  Offline
The Grand Daddy
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Joined: Mar 2005
Posts: 1,287
Somewhere in South of England
I would have thought the right to be forgotten doesn't apply to an HCM or Payroll system as the data is required as a legal obligation. The following is from the ICO (Information Commissioners Office).

The right to erasure does not apply if processing is necessary for one of the following reasons:
•to exercise the right of freedom of expression and information;
•to comply with a legal obligation;
•for the performance of a task carried out in the public interest or in the exercise of official authority;
•for archiving purposes in the public interest, scientific research historical research or statistical purposes where erasure is likely to render impossible or seriously impair the achievement of that processing; or
•for the establishment, exercise or defence of legal claims.

The GDPR also specifies two circumstances where the right to erasure will not apply to special category data:
•if the processing is necessary for public health purposes in the public interest (eg protecting against serious cross-border threats to health, or ensuring high standards of quality and safety of health care and of medicinal products or medical devices); or
•if the processing is necessary for the purposes of preventative or occupational medicine (eg where the processing is necessary for the working capacity of an employee; for medical diagnosis; for the provision of health or social care; or for the management of health or social care systems or services). This only applies where the data is being processed by or under the responsibility of a professional subject to a legal obligation of professional secrecy (eg a health professional).


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