"Management of leave" and "Management of Leave on Personal Grounds and Unpaid Leave" - CPVO

Joint opinion of 28 March 2011 on two notifications for Prior Checking concerning "Management of leave" and "Management of Leave on Personal Grounds and Unpaid Leave" at the Community Plant Variety Office (CPVO) (Cases 2010-0073 and 2010-0075)

The CPVO has implemented an automated system, the "Centurio Congé" database, for managing the annual and special leave entitlements of staff, while the processing of leave on personal grounds and unpaid leave is done manually in paper. In his prior checking opinion, the EDPS recommends that the handling of health-related data by HR staff, such as the processing of medical certificates, is subject to their signing of specific declarations of confidentiality that they are subject to an obligation of professional secrecy equivalent to that of a health professional. The EDPS reminds the CPVO that health data should only be processed by a health professional and therefore recommends that the CPVO instructs its staff to provide medical information directly to a health professional. The EDPS further recommends that the CPVO adopts appropriate time limits for the retention of personal data processed in paper.