What it asks for. Article 88 allows member states, by law or collective agreements, to provide more specific rules to protect employees' rights and freedoms in the processing of their personal data in the employment context, for example for recruitment, performance of the employment contract, health and safety, and termination. Such rules must include suitable and specific measures, particularly regarding transparency, transfers within a group and monitoring systems at work.
In practice. Organisations identify which national employment data rules and collective agreements apply in each country they operate in, and reflect them in HR processing, employee notices and workplace monitoring. Evidence includes country level legal analyses, employee privacy notices, works council consultations where required and DPIAs for monitoring tools.
Common gaps. Global HR and security monitoring tools are often rolled out uniformly without checking national rules. Consultation obligations with employee representatives are frequently missed.