In respect of a person to be notified in the event of an accident, if an employee consents to providing that person's data, must the information obligation be fulfilled? Should such data be treated as employee data?
ANSWER
Yes, at present there is no exemption in this regard. If the employer obtains from an employee the personal data of an emergency contact person, it is obliged to provide that person with the content of the privacy notice under Article 14 GDPR, as the data are obtained indirectly and not directly from the data subject.
