What personal data may an employer collect from witnesses of a workplace accident?

ANSWER

The regulations on accident documentation do not specify the scope of personal data that may be collected from a witness of a workplace accident. Since a witness's personal data may subsequently be used for court proceedings, it is reasonable to refer to Article 262 of the Code of Civil Procedure, which provides that for a court to summon a natural person to a hearing it needs their first and last name and home address.

This scope of personal data will therefore be necessary so that the person can be summoned as a witness to give testimony (both within accident proceedings and any potential court proceedings). The data minimisation principle under Article 5(1)(c) GDPR is respected in this regard, according to which personal data must be adequate, relevant and limited to what is necessary for the purposes for which they are processed.