Especially in large corporate groups or corporations, but also in small businesses, the company’s development plays a significant role. Even after many years, one wants to be able to track how the company has developed both in terms of numbers and projects. Major milestones reported in the press, as well as important internal events, can be particularly relevant. In this regard, it is understandable that companies would want to build a corporate archive in which information on development is permanently stored. Since important milestones are often associated with specific individuals, the storage of personal data is inevitable document company history.
Applicability of the GDPR document company history
It is essential to determine whether the GDPR applies to the processing in question. It should be noted that the GDPR only applies if the data subject is a living person. Content from company history that concerns deceased persons is not subject to the GDPR. Content that contains no personal reference whatsoever, i.e., purely information about the company and its processes, italy business fax list is also not subject to the GDPR. This content can be stored permanently. The following assessment only applies to content that contains personal data of employees or external parties (including author names, etc.).
Legal basis
The storage of personal data intended for archiving purposes can generally be based on a legitimate interest. If the data was previously collected and processed for other purposes, this also constitutes a change of purpose according to Art. 6 (4) GDPR, thus, the computer vision field was which is why the requirements may also need to be review.
In addition, the content must be examined to determine whether the legitimate interests of the data subjects may outweigh the legitimate interests. This is likely to be the case, especially with sensitive content. Information published in collaboration with the data subject (e.g., intranet or press) should generally not have any overriding legitimate interests. Beyond that, each individual case must be considered. Personnel documents or similar may not be archived under any circumstances. In particular, no personal data of special categories pursuant to Art. 9 GDPR (especially health data, etc.) may be stored.
Permanent storage
As already stated, in the case of internal archiving, the opening clause on which press companies can rely cannot be invoked. It remains the case that the principles within the meaning of Art. 5 GDPR must be observed. This also includes the principle of storage limitation pursuant to Art. 5 (1) (e) GDPR. There are no exceptions to this. Even for the press, botswana business directory the permanent storage of content is not generally justifiable. In the opinion of the Federal Constitutional Court, the dangers of the unlimited availability of information on the Internet must be taken into account when interpreting the Basic Law, even for the press (cf. BVerfG NJW 2020, 300 para. 104).
Information obligations
The data subjects must be informed in accordance with Art. 13 GDPR. In particular, the permanent storage of the content should be emphasized. Especially if the processing may affect all company content, it is recommended to supplement the data protection notices individual data protection information (e.g., displays at events, declarations of consent for photos/videos) should directly refer to the storage of the data for archiving purposes. In particular, the data subjects should be informed of their right to object.