Can referring employees pass on the CVs of people they refer to HR?

ANSWER

It depends on how the so-called referral programme is organised internally at the controller. A good practice is to organise such a process formally and describe the individual steps, e.g. by drawing up referral programme regulations. As regards referring employees passing CVs to the HR department, this is correct practice. Application documents should reach the persons in the organisation who are responsible for the recruitment process.