Can an employer disclose and disseminate the content of a reprimand imposed on an employee?

ANSWER

The Labour Code allows the employer to impose on an employee a reprimand, a warning or a financial penalty. The employer should inform the employee of the imposition of a penalty in writing. The employee may lodge an objection to that penalty within 7 days of being notified of the penalty imposed. However, information about the imposition of a penalty should not be publicised by the employer in the workplace, as access to such documents, together with personal data, may be had only by employees authorised to process personal data on behalf of the employer. Publicising such information among all employees of the workplace constitutes unauthorised disclosure of personal data under Article 4(12) GDPR.