Excessive data collected by jobs portal (2021-06-08)

Summary

This is a published case summary from the Cayman Islands Ombudsman describing an informally resolved data protection complaint against WORC's online Jobs Portal. It illustrates how the Ombudsman applies data minimisation principles under the Data Protection Act to online registration platforms.

• Complaint: An individual complained that WORC's Jobs Portal required her to provide her own personal data in order to set up a profile on behalf of her employer.
• Finding: The Ombudsman found the data controller had a valid legal basis for collecting some personal data, but that the amount collected from individuals setting up accounts solely to act on behalf of their employer was excessive.
• Outcome: The data controller (WORC) agreed to make technical changes to its platform to reduce the personal data collected from individuals acting on behalf of their employer, and to develop and publish additional registration guidance.

As an informal resolution case summary, this document does not itself create new binding rules for other entities, but signals the Ombudsman's expectations on data minimisation for online portals that collect personal data from individuals acting in a representative or operational capacity for a third party.

Key obligations

• WORC agreed to make technical changes to its online Jobs Portal to reduce the amount of personal data collected from individuals acting on behalf of their employer
• WORC agreed to develop and publish additional guidance on how to register on the online platform

Applies to

data controllers, online platform operators collecting personal data