Works Council as independent controller in terms of the GDPR
As long ago as June 2018, the question was raised in the expert forum on industrial relations law as to whether the works council itself is responsible for data protection within the meaning of the GDPR. Last spring, a resolution by the supervisory authorities on this issue had already been put forward. In spite of that, the question has not yet been answered, either by the supervisory authorities or by case law. On the contrary: there is even more discussion going on now than there has been in recent months. Dr. Carlo Piltz provides a summary of the current state of affairs.