Is Article 6 the legal basis for processing? There is an opinion that it is a condition and the legal basis is, for example, a provision of the Labour Code.
ANSWER
The provisions of the GDPR provide legal bases for processing and for sharing data in Article 6(1) GDPR (for ordinary personal data) and in Article 9(2) GDPR (for special categories of personal data).
Where processing is based on Article 6(1)(c) GDPR — processing is necessary for compliance with a legal obligation to which the controller is subject — the data controller should indicate the provisions of law that impose specific obligations on it, e.g. from the Labour Code, the Accounting Act, etc.
