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Trainee Data in the Company: Data Protection, Works Council, Security
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Training data is personal data according to the GDPR – often from minors and often with performance and behavioural relevance. Those who process it in an external system need an order processing contract according to Art. 28 GDPR, a reliable role concept and usually the participation of the works council according to § 87 para. 1 Nr. 6 BetrVG. This overview shows what a clean setup looks like. In many training departments, however, the reality i…
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