When posting employees' work-related data on a website, does the employer transfer data to third countries?

ANSWER

Employees' personal data in the form of their first and last name, work telephone number, work email address and job title constitute so-called work-related data, which are strictly professional in nature. They are not treated as a natural person's private data.

This means that the employer is entitled to publish such data, for example, on a website without obtaining separate consent from the employee for that specific processing purpose. When publishing such data on the employer's website, it must first be established whether the servers or the hosting company that operates the website are located in a third country. If so, such information must be included in the privacy notice for employees. If they are located in the territory of the European Union, there is no such requirement — information that data are not transferred to third countries will suffice.