In the DACH context, GDPR, national employee data protection rules and the General Equal Treatment Act (AGG) must be considered together. Recommendation: for review and escalation processes, establish fixed deletion periods, role-based access rights and audit logs. In practice: example 2 -- review cycle with audit log, KPI tracking and escalation path. Limitation: overly generic rules without role or legal context reduce quality. (Sources: EU Directive 2023/970 Pay Transparency, GDPR General Data Protection Regulation)
Sources & Data
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