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Company Contacts page

From what I understand, the contact information at work is not regulated by GDPR since it is considered B2B. For instance my private email is regulated by GDPR, but my work email is not. When my company has a contacts web-page what can actually be included without my consent?

  1. Name - yes
  2. Picture - yes
  3. Work email - yes
  4. Phone ???

Company paid cell phone

If I had a separate SIM card for my company paid cell phone, then I would agree it could be posted on the contacts page. Now it happens to be one of the fringe benefits of the company that they pay your cell-phone upto a certain amount. Does this give them the right to publish my number on their web-site without my consent?

  • Where are you? Do you pay for incoming calls? – Martin Bonner supports Monica Jun 15 '18 at 12:05
  • @MartinBonner I am in Norway. Europe generally does not charge incoming calls unless outside of EU. The cost is mostly the mobile data. – Per Digre Jun 15 '18 at 13:26
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    Why would your work e-mail not be regulated by GDPR? Which part of the regulation exempts a work e-mail address from consideration as "information relating to an identified or identifiable natural person"? Also, I am not aware that GDPR regulates the publication of data. I would expect that it continues to be governed by existing privacy protections. – phoog Jun 15 '18 at 15:40
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    @phoog I agree that a personal corporate email address is regulated by the GDPR. (And for the same reason a company paid phone number would also identify a natural person). But I also think that publishing data is regulated by the GDPR. It fits Art. 4(2) GDPR, the European Commission even includes the example posting/putting a photo of a person on a website. – wimh Jun 15 '18 at 21:02
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    @Per Digre In both cases consent is needed. And at least in Germany you are not allowed to be fired or any other disadvantages if you do not give consent. – Fabian Barney Oct 15 '18 at 4:38
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When my company has a contacts web-page what can actually be included without my consent?

If it would be on a intranet (ie. only visible inside your company), your name, picture, work email and work phone number can be put on that page. This is because it would be important that coworkers know each other and can contact each other.

On a public website (visible to anybody), the situation would be different. Basically I think nothing can be put on the web page without your consent. Everything is personal data, and there is no real reason to put it on the website. In some countries it is not possible to ask consent from employees, because it would never be freely given. In that case such a contact page is not possible at all.

However if you are part of the management team or sales team, there might be good reasons to put contact data on a public website. Those will be people which represent the company. So it might be important that (potential) customers see this information. However I can also imagine it would be sufficient to add all contact data (including a picture) just to email messages.

Now it happens to be one of the fringe benefits of the company that they pay your cell-phone upto a certain amount. Does this give them the right to publish my number on their web-site without my consent?

No, I don't see why that would change anything. If it is your private phone number, it would not even be ok for coworkers to get that phone number. Only the management might have reasons to contact you in your private time.

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    "it would not even be ok for coworkers to get that phone number". In other words our internal contacts directory is illegal ?? – Per Digre Nov 22 '18 at 8:16

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