The question that raises my doubts is whether the employer really has the purposes of processing vaccination data? In my opinion, the above-mentiond considerations lack a separate purpose for the processing of employee data by the employer in the entire vaccination process at the workplace. Activities relatd to the processing of personal data are carrid out in practice on behalf and for the purposes of the mdical entity.
Their personal data A clear and well
All the circumstances indicate that in the process. Of vaccination against Covid-19, the employer acts as a processor acting on behalf Latest Mailing Database of the mdical entity. There is also no justification and no reason why the employer would keep information in its resources which of its employees was vaccinatd against Covid-19. There is a risk that the employer, processing information about the employee’s vaccination for his own purposes, may violate Art. – the principle of data minimization.
To find out to whom they transfer
The processing of information regarding the employee’s health. May be classifid as inadequate to the circumstances. And purposes of Mailing Lead processing. The information obtaind from clients shows that the two largest healthcare. Entities on the private market use two different models. One of them requires concluding. An entrustment agreement with the employer. The second, in turn, firmly believes that each is a separate administrator and will not conclude any entrustment agreement. As you can see, the situation is dynamic. And developing, and the divergence of views. And models at the moment is really large.
