Are employers sometimes required to consult with works councils or trade unions to process employee's personal data?

Employers are indeed sometimes required to consult with works councils or trade unions before processing employees' personal data. This requirement is grounded in various labor laws and regulations, which can mandate that employer-employee relationships include collective bargaining and consultation processes. Such consultations help ensure that the processing of personal data is justified and transparent, considering employees' rights and expectations regarding privacy.

In many jurisdictions, particularly within the European Union, works councils have a crucial role in protecting employees' interests. They can influence decisions regarding the processing of personal data by representing employees' viewpoints and ensuring that any data usage aligns with collective agreements.

The need to consult might depend on various factors, including the nature of the data being processed, the company's policies, or specific labor agreements. However, it is a common practice and often a legal obligation in many contexts where employee data is involved, ensuring that employees have a voice in how their personal information is handled by their employers.