Netherlands: AP objects to draft bill for the supervision of the prevention of discrimination in recruitment
The Dutch data protection authority ('AP') issued, on 14 January 2020, its opinion ('the Opinion') on the draft bill for the supervision of the prevention of discrimination in recruitment and selection ('the Draft Bill'), whereby it objected to the proposals through highlighting that, when disclosing personal data, the violation of the interests of the data subjects must not be disproportionate to the purposes of the disclosure. In particular, the Opinion outlines that the Draft Bill requires the public disclosure of information regarding an administrative fine, such as the name of the employer or intermediary, the place of business, and the nature of the violation. The AP advises that the proposed disclosure of such personal data must meet the proportionality requirement, and must weigh the interests of the disclosure with the interests of involved parties.
Furthermore, the AP notes that certain purposes, such as the promotion of compliance and legitimising the conduct of the supervisor, can be achieved through the disclosure of anonymised and pseudonymised data.
You can read the Opinion, only available in Dutch, here.