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    Who is entitled to inspect the holiday balance per employee?

    Senior management has requested access to the time off balance of individual employees. It seems to me that only an employee and his direct manager are permitted access to this balance, right?

    Correct! The General Data Protection Regulation (GDPR) applies in this instance because obtaining access to an individual’s time off balance is considered the processing of personal data. Although the GDPR does not specify which people within an organization have access to certain data, it does lay down that the processing of data is only permitted if it complies with the regulation’s principles.


    The processing of personal data requires a specific purpose and no more personal data may be processed than is necessary for this purpose. Although it is important for the employee and his/her direct management to have access to the employee’s time off balance, it is questionable whether this is also the case for senior management. It can be argued that access to time off balances is not required to fulfill the role of senior management. Even if senior management has taken on a task for which access to time off balances is required, it can be argued that the principle of data minimalization laid down by the GDPR is not met. For example: if senior management is given access to the time off balance of individual employees in order to avoid staff from accruing too much vacation time, data is processed which is not required for this specific purpose – i.e. senior management now knows how much vacation time each individual employee has, rather than staff all together. In this instance, it is more in line with the principles laid down by the GDPR to provide senior management with an overview of aggregated data instead, so that it is no longer possible to trace back specific vacation time to an individual employee.

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