For employers, pay transparency means more than just new obligations to provide information to employees. Significant changes also concern the scope of pay information to which workplace trade union organisations may gain access.
Whilst employees will primarily be able to access general information on pay levels, trade unions may gain significantly broader access to pay data. This raises questions about how such information is to be provided and the risk of disclosing data relating to the pay of specific employees.
As Renata Bugiel points out, it will be crucial for employers to properly prepare procedures relating to the disclosure of pay information. Companies should ensure, amongst other things, that there are appropriate rules governing access to data, that the data is secured, and that the risk of unauthorised disclosure is minimised.
In a commentary for Prawo.pl, Ms Bugiel explains what steps employers can take to minimise the risk of salary data leaks and prepare for the new realities surrounding pay transparency.
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