GDPR training for HR teams: what should it include?

GDPR training for HR teams: what should it include? the general data protection regulation is not just a compliance obligation to tick off for HR teams. it touches the core of your work: from the first job application to the final exit interview, HR professionals process sensitive personal data daily. A data breach, incorrectly stored absence records, or careless handling of reference checks can not only lead to fines of up to 20 million euros, but also to reputational damage and loss of trust among employees. yet in practice, many HR teams mainly have theoretical knowledge of the gdpr, without a clear understanding of what it concretely means for their daily work. an effective GDPR training for HR therefore goes beyond legal principles. it translates legislation into recognizable HR situations and provides concrete tools for safe data processing.

Why standard GDPR trainings fall short for HR

Most general privacy trainings cover the GDPR from a broad organizational perspective. That makes sense, but is not very practical for HR professionals. You don’t work with customer databases or marketing data, but with employment contracts, performance reviews, absence records, and salary information. Each with its own retention obligations, processing grounds, and risks. An HR employee who knows what the six grounds of the GDPR are, but doesn’t understand when you do or don’t need consent from an applicant, has little use for that knowledge. The translation from theory to HR practice is often missing. That’s why specialized GDPR training for HR teams is essential, not optional.

The basics: personal data in HR context

A good GDPR training for HR starts with recognition. What exactly is personal data in your field? It goes beyond obvious things like name, address, and social security numbers. Assessments, notes from performance reviews, employment conditions, training history, and even the information that someone is applying also fall under this. Special categories of personal data deserve extra attention in the training. Think of medical information related to absence, union membership, criminal records when screening certain positions, or religious beliefs in leave requests. This data may only be processed under strict conditions and requires additional security measures. The training must teach HR employees to recognize this data in their daily work. Documenting an absence conversation, conducting a reference check, or creating a personnel file: these are all moments when you need to be aware of what you’re recording and why.

The six grounds: when may HR process data? the GDPR has six lawful grounds for data processing.
for HR, three grounds are particularly relevant and must be clearly explained in the training. the performance of the employment contract is the most important ground. this allows you to process data necessary for the personnel file, payroll administration, and leave registration. but be careful: not everything falls under this. A question about hobbies or future plans during a performance review is not necessary for the employment contract. legal obligations form the second important ground. think of the obligation to pay wage tax, register working hours, or maintain absence records. this ground provides clarity, but here too: only what is truly legally required. consent is the third ground, but this is where things often go wrong in HR. consent must be freely given, but with an unequal power relationship between employer and employee, that’s difficult. an employee who is asked for consent for a company photo doesn’t always feel free to say no. the training must teach HR professionals when consent is and isn’t suitable as a ground.

Privacy rights of employees in practice

Employees have various rights under the GDPR, and HR teams need to know how to handle them in practice. The right of access means that an employee can ask what data you process about them. Sounds simple, but in practice this raises questions. Should notes from an informal conversation also be shared? What about references from a previous employer? The right to rectification and erasure requires clear procedures. What do you do if an employee asks to delete a negative assessment? Or if a former employee wants all data erased, while you have a legal retention obligation for salary data? The training must cover concrete scenarios and provide clear answers. Not just theoretically, but with examples from HR practice. Which forms do you use? Within what timeframe must you respond? And how do you communicate this to the employee?

Retention periods: what must go and what must stay? one of the most practical parts of a GDPR training for HR concerns retention periods. the GDPR stipulates that you don’t retain personal data longer than necessary, but what does that mean concretely? for application data of rejected candidates, four weeks usually applies, unless the candidate gives consent for a talent pool. personnel files of departed employees must be retained for at least two years due to possible legal claims, but some parts longer due to tax obligations. absence data has different periods again. the training must give HR teams a practical overview of relevant retention periods and explain how to set up a system to ensure this. which reminders do you set in your system? how do you archive in a way that makes it easy to clean up after the retention period? these are the questions that arise in daily practice.

Recognizing and reporting data breaches

Not every incident is a data breach in GDPR terms, but HR employees must know what the signals are. A CV accidentally sent to the wrong recipient, an unsecured USB stick with salary data that gets lost, or an email with absence data sent in cc instead of bcc: these are all potential data breaches. The training must clarify when something must be reported to the data protection officer or directly to the Data Protection Authority. A data breach must be reported within 72 hours if there is a risk to the data subjects. That sounds like a lot of time, but in practice it goes quickly. More important is prevention. Which situations are risky? How do you secure data when working from home? What do you do with paper files? And how do you safely handle data in video calls or when using new HR tools? These practical examples must be extensively covered.

New employees, exit, and everything in between

A good GDPR training for HR follows the employee journey and shows where the privacy risks are at each stage. In recruitment and selection, it’s about limiting requested data, secure storage of applications, and correct handling of rejections. During employment, other issues arise. How do you handle monitoring and control? May you view email traffic in case of suspected abuse? How do you document an improvement process without violating privacy? And what are the rules during reorganizations where data is shared with social partners or a new employer in case of transfer of undertaking? At exit, the question arises of what you retain and what you delete. The transfer of data to a new employer also requires care. What information may you share in a reference? And how do you handle a departing employee who wants all their data erased?

Working safely with HR systems and tools

The digitalization of HR brings efficiency, but also privacy risks. A GDPR training must pay attention to safe use of HR systems, recruitment systems, assessment software, and other tools. Important questions to be covered: where is the data stored? Has the supplier signed a processor agreement? Who has access to which data? And how do you prevent employees from seeing more than necessary for their role? Also practical matters such as password policy, two-factor authentication, locking your screen, and safe printing belong in the training. It sounds basic, but in practice things regularly go wrong here. An unlocked screen with open personnel files, printed salary overviews left on the printer, or a shared login for the HR system are risks that are easy to prevent.

From theory to behavior change

An effective GDPR training for HR doesn’t stop at knowledge transfer. The goal is behavior change. That’s why the best trainings work with concrete cases, role plays, and practical exercises that are recognizable to participants. Have participants practice responding to an access request, assessing whether a new HR tool is GDPR-proof, or drafting a processor agreement. Discuss dilemmas that arise in your organization. The more the training aligns with daily reality, the better the knowledge sticks. A clear follow-up process is also important. Who can employees contact with questions? Where do they find templates and checklists? And how do they stay informed of developments? Privacy is not a one-time project, but a continuous process.

The investment that pays for itself

A thorough GDPR training for HR teams costs time and money, but the investment pays for itself quickly. Not only do you prevent potential fines and legal claims, but you also build a culture of diligence and trust. Employees who know that their employer handles their personal data carefully have more trust in the organization. And HR professionals who know exactly what is and isn’t allowed work more efficiently and with more confidence. Start with a thorough inventory of current knowledge and practice within your HR team. Which parts of the GDPR are clear, and where are the biggest knowledge gaps? Based on that, you can compile or purchase a training that truly meets your needs. Ensure the training is practical, interactive, and specific to HR. General privacy trainings simply don’t suffice for the complex data processing that HR deals with daily.