EDPB Guidelines 05/2020 on consent, para 21: employee consent is rarely free (EDPB Guidelines 05/2020 on consent under Regulation 2016/679, Version 1.1, adopted 4 May 2020, para 21)
A holder cannot fix staff emails, chats or recordings by asking employees to consent, because that consent is unlikely to count. It needs another basis, or it should leave employee content out of the lot.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“Therefore, the EDPB deems it problematic for employers to process personal data of current or future employees on the basis of consent as it is unlikely to be freely given.”
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