"Recruiting Great People Daily SA", the French headquartered recruitment agency (CAC: DPZGP) became one of the first GDPR casualties of the recruitment world.
"Recruiting Great People Daily SA" hired a GDPR expert ahead of May 25th 2018. As an expert, he found a large number of personal data on the CVs handled. He identified that the name and past positions were passed to the recruitment consultants. "This could be a breach of the principle of data minimisation" he confirmed. The GDPR expert knows what he is talking about as last December, he advised a white-bearded CEO often dressed in red on how to comply with the definitions set in Article 4 - a tedious task.
He initially suggested shredding the CVs as a pseudomisation method. The recruitment agency's DPO, Humpty D was against the idea. Mr 'D' cannot be named in fear of a data breach, but the expert agreed to reveal his surname in encrypted format 'B9BF142CC55E1CA70388C41734170576ACBA58A0099E8EE7FD20D680EA4A2770'. The reason Mr 'D' evoked was the cost of putting the CVs back together again as it would be too time consuming for the busy staff.
The GDPR expert then suggested to photocopy the CVs with a white sheet in front of the text. This clever solution meant the CVs no longer contained personal data. After a few experiments, the GDPR expert found a trick to save time: the recruitment staff could pick-up a blank CV from the paper tray of the photocopier and wouldn't need to press the Copy button. For the DPO, under huge budget constraints, this proved to be the best solution.
This solution worked well, but created a challenge when candidates exercised their rights under Article 15 of the GDPR. A lot of candidates complained that the copy of the CVs supplied were not theirs. Being all identical created a real challenge when trying to identify the data-subjects. A class-action was filed with the office of the French data-protection commissioner in the hope they could get a jackpot similar to the Google fine in January.
The French Data Protection Commission investigated and fined them 20 million euro, which far exceeded "Recruiting Great People Daily SA" savings.
"Recruiting Great People Daily SA" went bankrupt and the CEO said in a final press release "Bloody GDPR, we did all we could to be compliant, hiring a badged GDPR expert, followed his recommendations and still got fined. We can't run a business under these conditions". The former CEO and the DPO have started an on-line petition to revoke GDPR.
Moral of the story: Don't trust the GDPR Expert's badge blindly.
Picture: sample "GDPR badge", courtesy of Mr Dave 7073D36FCDF2D56F4A7658DFDBEB6B1213D9F0586D3A188AE7EBA40B3EE5A101.
PS: Although this may seem like a "plausible" story to some, we'd like to clarify it is a made-up story for April Fools' Day 2019 and that to our knowneldge such company does not exist. The acronym of the company is RGPD, French acronym for GDPR.