Justification for the use of Howdy
Exchange of data (according to GDPR)
The customer must clarify whether they can invoke legitimate interests in the use of Howdy.
Howdy’s lawyers (Lundgrens Advokatpartnerselskab) assess that:
- All companies and the like can invoke legitimate interests as justification for the use of Howdy.
- Public authorities may use section 12 of the Data Protection Act as a legal basis for processing, including disclosure, in Howdy. §12 mentions that a data controller may process data covered by GDPR Articles 6 and 9 in order to comply with obligations and / or pursue rights arising from employment and labor law legislation and / or collective agreements, e.g. the obligation to offer a safe and healthy working environment.
It should be noted that the customer’s legitimate interests only relate to the fact that Howdy addresses the company’s employees in order to offer registration for the Howdy solution. The employee’s actual use of the solution takes place with the explicit consent that the employee himself gives to Howdy before access to Howdy is granted.