Data Protection in the Context of Payroll - Page 6 of 14

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Data Protection Principle 3 - Adequate, relevant and not excessive

Personal data shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed.



Although a data controller may have a register entry that permits the processing of certain kinds of personal data, this Principle introduces a further consideration. Is the data used, or just obtained in case it might come in useful in the future? Is the data sought because it is interesting but, in practice, it is not essential or relevant to the purpose? Since the data was collected, has it now become redundant? Is data being collected for all employees when, in fact, it is only used for a certain group of employees?

These questions do not generally apply to payroll data as most payroll systems only hold information that is essential for payroll processing. An example of potentially redundant data in a payroll system is "marital status", as it serves no specific payroll validation purpose, other than possibly for women paying reduced-rate NICs. Some systems, however, are designed to hold additional "personnel" data, so the above questions should be considered in that situation.

Even though a payroll system has fields to record various items of information about an employee, it does not necessarily mean that they all have to be used. A payroll system will normally indicate which items must be recorded for statutory purposes, but the use of any others should be a decision that is made in the light of the Data Protection Principles.

Redundant data should be deleted, as required by Principle 5.

© Ian Congreave and Paypershop Ltd

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