On February 11, 2014, the French data protection authority (CNIL) published Deliberation #2014-042 and expanded the list of issues that a whistleblowing program may permissibly receive and process under French privacy laws. Now, these programs also can be used to report employment discrimination and harassment, and health, hygiene, safety and environmental issues. This is a significant development under French privacy law because, up to this point, the Single Authorization No. 4 strictly limited the type of data that French subsidiaries and other companies operating in France could collect. In particular, companies only could receive reports concerning finance, accounting, banking, anti-corruption, and unfair competition. A program that was constructed to receive reports concerning employment discrimination or harassment, for example, was technically in breach of French data privacy laws. Under Deliberation #2014-042, this is no longer the case. For full coverage of these developments, please read: Whistleblowing and Data Privacy in France: A New Pragmatic Approach for Employment and Discrimination Claims.
CNIL Expands Scope of Whistleblowing Programs under French Privacy Law
By Jilali Maazouz and Myrtille Lapuelle on February 26, 2014
Posted In Data Privacy
Jilali MaazouzJilali Maazouz advises US, European, Asian, Canadian, Middle Eastern and North African multinational corporations on the labor and employment aspects of their French and transactional commercial and corporate transactions, as well as on their restructuring plans, reductions in force, separation agreements, workplace policies, due diligence investigations, audits, top executives' compensation and benefits packages and mobility, and employment contracts engineering. Jilali also focuses his practice on commercial disputes and international trade matters. Jilali represents clients in negotiations, alternative-dispute resolution proceedings and litigation, in a range of civil, commercial, criminal and administrative matters. Read Jilali Maazouz's full bio.
Myrtille LapuelleMyrtille Lapuelle draws on her extensive experience—covering the full array of labor-law matters—to advise international companies and groups on daily issues as well as on complex operations. Myrtille has developed a specific focus in the collective aspects of labor law. She has gained in-depth understanding of advising corporate groups in the area of restructuring plans, and regularly counsels clients throughout the entire restructuring process. Read Myrtille Lapuelle's full bio.
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