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Are employees' business records confidential?

Jellinghaus, Steven
19 March 2019

Question & Answer

ANSWER

Art. 4 paragraph of the AVG states that the concept of personal data includes any information about an identified or identifiable natural person. The latter refers to data that can be directly or indirectly traced to a particular person. The AVG has no exception for business data. Name and business e-mail address (if it contains a name) are therefore also personal data within the meaning of the AVG and their processing must comply with the AVG.