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Just over a year has passed since the European Union’s General Data Protection Regulation went into effect May 25, 2018. Companies doing business in the EU or who have vendor or employer relationships with EU-based individuals need to continue to evaluate their GDPR obligations.

GDPR replaced the EU’s Privacy Directive, which had been in place since 1995. It also instituted several significant changes such the “right to be forgotten,” requiring data portability, enhancing data subject access rights, and creating dramatic fines for violations. Significantly, GDPR’s extraterritorial scope means it reaches entities that were previously not necessarily bound by the Privacy Directive. Companies in the U.S. and elsewhere need to take note and evaluate whether, in their rush to comply with GDPR with respect to e-commerce and other consumer data, they haven’t overlooked their human resources data as well.

It is critical to recognize that GDPR applies to any company that “monitors” the behavior of individuals located within the EU. The GDPR doesn’t define “monitor,” but human resources functions such as tracking workers’ activities in order to review their performance, reimbursing expense claims, tracking time (the European Court of Justice recently held that EU employers must track time for all employees) and administering leave programs require some degree of monitoring. Thus, a multinational that has contractors or employees in the EU has obligations under GDPR even if it doesn’t have an EU presence or sell goods or services into the EU and even if its EU-based employees are not EU citizens.

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