Data Protection Module (Works Council Edition)
Stronger Data Protection for Works Councils.
The Data Protection (Works Council) Module—or "Datenschutz (BR)" in German—is specifically designed for organizations with an active works council in Germany. It helps both employers and works councils meet their data protection obligations under § 79a of the German Works Constitution Act (BetrVG). From defining cooperation agreements between employer and works council, to documenting all data processing activities and privacy-relevant procedures within the works council, the module provides end-to-end support. It also includes tools for training and raising awareness among all council members—ensuring privacy compliance is both structured and practical..
Privacy-compliant Collaboration on Equal Footing.
The employer’s role as the data controller and the works council’s legal independence often create practical challenges in implementing data protection measures. The Data Protection (Works Council) Module offers a pragmatic solution to navigate these complexities. It helps defuse potential points of conflict and enables both parties to meet their respective data protection obligations—legally compliant and resource-efficient.
Complex Requirements. Simply Solved.
All Essential Features at a Glance.
Works Council Processing Activities
Works councils can document and assess their data processing activities in a dedicated register. They can also link these activities to data processors or recipients outside the EU to map data flows accurately and maintain transparency.
Works Council Processor List
Data processors engaged by the works council to handle personal data can be recorded and assessed in a dedicated processor list. Each processor can be linked to specific processing activities, enabling a clear view of responsibilities and data flows.
Works Council Data Transfers to Third Countries
Data transfers by the works council to recipients outside the EU can be documented in full compliance with the GDPR. This includes all relevant details such as recipient entities, legal bases, appropriate safeguards, and implemented protective measures.
Technical and Organizational Measures of the Works Council
Technical and organizational measures (TOMs) implemented for the protection of personal data processed by the works council can be independently documented and assessed in a structured manner.
Exclusive Knowledge Blog for Works Councils
An integrated, members-only blog provides works councils with in-depth information, practical guidance, and clearly explained expert insights on all aspects of data protection in the works council context.
Exclusive eLearning Courses for Works Councils
All works council members receive exclusive access to engaging and interactive eLearning courses focused on the unique data protection requirements that apply to works council activities.
Training and Awareness Measures
Planned and completed training and awareness activities for works council members on data protection can be independently tracked and documented in a verifiable manner.
Data protection holds special importance for works councils. With the Data Protection (Works Council) Module, works councils can establish a fully compliant privacy framework—quickly and with minimal complexity. Pre-built templates tailored to the legal and operational realities of works councils make it easy to document processing activities without unnecessary administrative burden. Complementing this, the module includes integrated eLearning and a curated knowledge blog focused on “Data Protection in Works Councils”—equipping members with everything they need to act in full compliance with the law.
Ines Bock, LL.M.
Senior Privacy Consultant
The Right Answers to Your Questions
The Data Protection (Works Council) Module is designed for organizations with an active works council that want to ensure legally compliant and transparent data protection documentation.
It is ideally suited for:
- Works councils that wish to independently and securely fulfill their documentation obligations under § 79a of the German Works Constitution Act (BetrVG) in a structured and compliant manner.
- Employers who are legally accountable as data controllers and want to document data protection obligations related to works council activities in a GDPR-compliant way.
- Organizations aiming to clearly separate the works council’s data protection responsibilities from broader corporate privacy management requirements.
With its purpose-built features—ranging from tailored questionnaires, templates, and sample documents to exclusive training content—the Data Protection (Works Council) Module is the ideal solution for both employers and works councils seeking to fulfill their § 79a BetrVG obligations in a structured and resource-efficient manner. It also serves as a valuable extension to the standard Data Protection Module.
The module is designed to allow the works council to fulfill its data protection obligations independently and autonomously. A flexible permission and access model lets both the works council and the employer define who has access to which content.
The works council can document its processing activities, training records, and privacy-related measures independently—without the employer gaining insight into internal works council processes.
At the same time, the employer—as the legally accountable data controller—can meet its own documentation obligations without interfering with the works council’s internal organization. With the Data Protection (Works Council) Module, the works council remains legally independent and organizationally flexible.
The Data Protection (Works Council) Module helps defuse potential areas of conflict between employers and works councils by establishing clear structures and binding processes that ensure transparency and legal certainty for both parties. To support this, the module includes a field-tested agreement template that enables employers and works councils to define the terms of their collaboration on data protection.
This framework helps both sides clarify roles and responsibilities around key compliance questions, such as:
- Who is responsible for which data processing activities?
- How are privacy-related documents created, maintained, and protected?
- Who responds to Data Subject Access Requests (DSARs) concerning personal data processed by the works council?
- Who fulfills the legal information obligations when the works council processes personal data?
- Who documents privacy incidents that occur within the works council’s area of responsibility?
- Which Technical and Organizational Measures (TOMs) must be implemented independently by the works council?
- How are works council members properly trained and made aware of their data protection responsibilities?
By defining responsibilities, aligning processes, and enabling transparent documentation, the module helps avoid misunderstandings and mitigate potential disputes—laying the foundation for a privacy-compliant and collaborative working relationship on equal footing.
Yes, the module comes with pre-built, field-tested templates for many common processing activities carried out by works councils. These can be used as-is or adapted to your organization’s specific needs—making it easier to get started, stay organized, and save time on documentation.
In addition, the module includes a template for a works council agreement, enabling employers and works councils to define the terms of their data protection collaboration in a structured and consensus-oriented way.
You'll also find practical reference materials, such as guidance on handling data subject requests or properly deleting personal data in compliance with legal requirements. You can also create, customize, and reuse your own templates—perfect for consistent and efficient documentation of recurring processes or organization-specific privacy needs
The Data Protection (Works Council) Module is specifically designed for organizations with a works council. It takes into account the works council’s independent legal status while also enabling the employer to meet its own data protection obligations as the legally accountable controller—without compromising the works council’s autonomy.
Unlike the standard Data Protection Module, the Works Council Module uses questionnaires tailored to the specific role, responsibilities, and legal context of works councils. This ensures that council members only see questions relevant to their actual duties—resulting in clear, compliant documentation with minimal administrative overhead.
In short: privacy-related processes are documented accurately, legally sound, and with full respect for the special regulatory environment in which works councils operate.
Additional features exclusive to the Data Protection (Works Council) Module include:
- Independent documentation and assessment of processing activities, data processors, third-country transfers, Technical and Organizational Measures (TOMs), as well as training and awareness programs tailored templates and sample documents for processing activities and privacy notices
- Exclusive eLearning courses on data protection for works council members
- A dedicated knowledge blog with hands-on guidance and easy-to-understand expert insights on “data protection in the works council context”
Yes, DSN port is built on a modular architecture. You can use the Data Protection (Works Council) Module on its own or combine it flexibly with other modules. For example, if the employer is already using the Data Protection Module, the Data Protection (Works Council) Module serves as the perfect complement.
While the standard module covers general corporate data protection, the Works Council Module is specifically tailored to the needs and responsibilities of works councils. This means that employers can fulfill their legal obligation to maintain a compliant record of processing activities, while works councils manage their own data protection documentation independently and in a structured manner.
By combining both modules, organizations benefit from clear, compliant, and transparent collaboration between employer and works council.
Our Data Protection Solution for Employers and Works Councils
The Data Protection (Works Council) Module helps employers and works councils fulfill their documentation obligations under § 79a of the German Works Constitution Act (BetrVG)—efficiently, consistently, and with minimal administrative effort. It includes works council-specific templates, sample documents, and guidance materials to support structured and compliant documentation. .
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