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Hungary: NAIH issues guidance on storage of employee documentation in line with ISO Standard

On April 12, 2023, the National Authority for Data Protection and Freedom of Information (NAIH) issued guidance on the storage of employee documentation in line with the ISO Quality Management Systems Standard (the Standard). The NAIH clarified that it received a question regarding the storage of documents certifying the employee's education on a protected server based on its legitimate interests. In particular, the NAIH confirmed that data controllers can legally copy documents on the education and training of employees if they only make copies of the personal data that they are otherwise entitled to handle in connection with the employment relationship.

The NAIH highlighted that the Standard does not provide the range of documents that the organization must be able to present; therefore, the organization must be able to define these documents independently. To this end, the NIAH provided best practices for determining the range of documents and clarifies data retention is primarily linked to the purpose of data management in line with the General Data Protection Regulation (GDPR). Notably, the NAIH clarified that the handling of copies of documents certifying education in order to comply with a standard cannot, as a rule, take precedence over the rules of the Labor Code. 

You can download the guidance, only available in Hungarian, here.