Apparently a typical German problem:How to handle the tax mandate in terms of data protection?
Just using the words “data”and “order”appears to instantly bring Art. 28 GDPR to mind.A tax consultant’s activities are governed by specific legislation and his own professional code of conduct, regulating what he is allowed to do and how to provide these services.Viz. independently (i.e. not bound by directives) and on own responsibility.Taking these statutory stipulations into account, the BayLDA [Bavarian Data Protection Authority] in FAQ published on 20 July does not classify tax consultancy, including the compilation of wage and salary accounting within the framework of consultation, as order processing.It may be assumed that a uniform nationally coordinated clarification can be expected, to avoid professionals falling into unprofessional practices.
Author: Rudi Kramer