Under Hungarian laws, the processing of employee personal data is subject to the special conditions and limitations of the Labour Code due to the likely subordinated position of employees within the context of employment. According to the case law of the Data Protection Commissioner, data quality requirements of the Data Protection Act must be interpreted in the light of the provisions of the Labour Code having cumulative effect with respect to the protection provided for workers under general data protection laws harmonised by the European Data Protection Directive. According to the prevailing opinion, the provisions of the Hungarian Labour Code are specific in relation to the general rules of the Data Protection Act. However, it causes several ambiguities in practice that the Hungarian Labour Code does not have any provisions specifically dealing with data protection issues within the context of employment. (more…)