What can we do with photos of the employees?
The Human Resources Department (HRD) of a private company kept a photo of each employee in their personal file, which allowed them to make up their identity cards.
Without asking permission, the HRD puts these pictures up on the website of the organization.
When the employees realized this and during a lively coffee break they opposed this publication.
An employee filed a complaint for violation of his image rights.
Authorisation is required from the employees concerned when their photos are used.
Recommendations
The publication of photographs of employees cannot be done without their consent, even if the employer has these photos for other purposes, unless a legal basis provides for such a publication.
Basic principles
LIPAD 35 and 36 ; LPD 4, 7, 14, 18a
Principle of transparency of data collection: the purpose of the collection must be recognizable and the data collected cannot be used for other purposes; principles of proportionality and data security (privacy, limited access).
Resources
