Polish Data Protection Authority reaffirms personal data rules when recruiting


The Polish Data Protection Authority (‘UODO’) 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’.

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