Is an employee obliged to provide their first and last name in relations with the employer's client?

ANSWER

An employee's personal data in the form of their first and last name, job title, work telephone number or work email address constitute personal data closely linked to their professional role. They are not treated like a natural person's private personal data. In practice this means that the data controller (employer) may, for example, publish such data on its website or provide such data as contact details in contracts or relations with clients without obtaining separate consent from the employee for that purpose. The same applies in the situation described — the obligation to provide data at a client's request.

As a rule, the work-related data indicated above should be provided by the employee at a client's request. However, the final decision in this respect should be taken by the employer depending on the business profile in which it operates. As a rule, the employer should implement appropriate procedures on how to deal with clients and indicate to employees which personal data should be provided to clients in such cases and how to deal with clients in a given industry.