GDPR Data processing modelCareer and mobility monitoring

By: Dastro Naute

Function: Human resourcesOrganisation: PrivateOrganisation: Public

Processing of employee data for professional appraisal, skills management, strategic workforce and skills planning, internal mobility and career development, and the administrative follow-up of occupational health appointments.

Purposes (6)

A purpose is the objective pursued by the setting up of your file. It indicates what the processing of personal data will be used for, its purpose. This purpose must be clear and understandable

Professional evaluation of personnel

Professional evaluation of personnel, in compliance with the legislative, regulatory or contractual provisions governing it

Legitimate interest

The organisation has a legitimate interest in managing its human resources effectively and ensuring workforce planning.

Management of internal professional skills

Legitimate interest

Organization of the professional activity.

Strategic workforce and skills planning

Legitimate interest

Organization and optimization of the professional activity.

Career mobility management

Contract

Processing is necessary for the performance of the employment contract.

Recognition of prior learning and professional experience

Legitimate interest

Legitimate interest in supporting employees' professional development and the recognition of their experience and qualifications.

Administrative follow-up of occupational health appointments and health surveillance

Legitimate interest

Article 6(1)(f) UK GDPR for occupational health referrals made by the employer or requested by the employee; Article 6(1)(c) where health surveillance is required by the Management of Health and Safety at Work Regulations 1999, reg. 6. Health data: Article 9(2)(b) UK GDPR with Data Protection Act 2018, Schedule 1, Part 1, paragraph 1 (employment, social security and social protection).

Data categories (3)

Personal data is any information relating to an identified or identifiable natural person. A natural person can be identified either directly (eg surname and first name) or indirectly (eg phone number, social security number, email or postal address, but also voice or image)

Professional evaluation of the employee

No statutory period for appraisal records; retention is based on the purpose and on the limitation period for claims (Limitation Act 1980, s.5). See Information Commission (ICO) guidance on keeping employment records.

Data details

Career development forecastsrequired

Employee's comments and wishesrequired

Assessment of professional skills on the basis of objective criteria with a direct and necessary link to the jobrequired

Results obtainedrequired

Assigned objectivesrequired

Professional skills of the employee

required

Identity of the evaluatorrequired

Dates of the evaluation interviewsrequired

Data conservation rules

Active base:

Time necessary for the achievement of the purpose

Limitation Act 1980, s.5

Intermediate archiving:

Up to 6 years after the employee leaves the organisation, to defend potential claims (Limitation Act 1980, s.5).

Destruction

Employee's identity

Data details

Type of driver's license

required

dependent children

required

Marital status

required

Family situation

required

Passport numberrequired

Personal contact information

optional

Professional contact information

required

Nationalityrequired

Photography (optional)optional

Date and place of birthrequired

Genderrequired

First namerequired

Last name

required

Data conservation rules

Active base:

The data necessary for personnel management are kept, in principle, for the duration of the employment relationship, unless otherwise provided by law or regulation.

Limitation Act 1980, s.5

Intermediate archiving:

Up to 6 years after the employee leaves the organisation, to defend potential claims (Limitation Act 1980, s.5).

Destruction

Employee career management

Data details

Disciplinary sanctions excluding those resulting from amnestied actsrequired

Employee's employment desiresrequired

Career simulationrequired

Purpose and reason for changes in the employee's employment statusrequired

Daterequired

Date and terms of recruitmentrequired

Data conservation rules

Active base:

The data necessary for personnel management are kept, in principle, for the duration of the employment relationship, unless otherwise provided by law or regulation.

Limitation Act 1980, s.5

Intermediate archiving:

Up to 6 years after the employee leaves the organisation, to defend potential claims (Limitation Act 1980, s.5).

Destruction

Data subject (2)

A data subject is any person whose data is collected, retained or processed by the data processing. e.g. In a recruitement process, any candidate for a position proposed in recruitement management process

Employees
Former employees

Author:

Dastro Naute

Created at:11/13/2021

Updated on:10/05/2026

Nb using:47