Processing of personal data in frame of deductions from salary in the event of a strike - ECB

According to Article 1.4 of the ECB Staff Rules, staff members at the ECB have a right to strike. Article 1.4.5 provides that "Unless the Executive Board decides otherwise, the total period of the strike shall be deducted from the salary related payments of the member of staff taking part in the strike".  Furthermore, "no disciplinary action may be taken against any member of staff participating in a strike unless the member of staff has been nominated to provide the minimum services described above and fails to do so in order to take part in the strike" (Article 1.4.7).

Article 27(2) of the Regulation contains a list of processing operations that are likely to present specific risks to the rights and freedoms of data subjects by virtue of their nature, their scope or their purposes such risks. This list includes, under paragraph (d), the "processing operations for the purpose of excluding individuals from a right, benefit or contract". To the extent that the participation to a strike automatically entails a deduction from salary and other allowances in accordance with Article 1.4.5 of the ECB Staff Rules, the processing of personal data related to that deduction is subject to prior checking by the EDPS.