GREECE Law and Practice Contributed by: Semina Zavitsanou, Yannis Ragos, Maria Siraga and Panagiota Kelali, POTAMITISVEKRIS
In certain circumstances, employers must escalate matters to the authorities (see 2.2. Communication to Authorities for further details). This includes cred - ible indications of criminal conduct, serious health and safety breaches or mandatory reporting obligations that arise under specific regulatory frameworks. In harassment and violence cases, employers may need to notify labour authorities if the complainant opts to pursue a formal complaint before them. In other situations, employers may choose to involve authorities if the investigation uncovers risks that extend beyond the workplace or if transparency is necessary to limit legal exposure. The type of infor - mation shared is usually limited to the essential facts and steps taken to address the issue. 6.7 Other Communications Employers may update individuals who assisted in the investigation, such as witnesses, particularly when their co-operation was essential, although it is not a common practice in Greece. These communications are usually brief and confirm only that the investiga - tion has concluded, without sharing confidential or personal details. Managers or team leaders may also receive limited information when they need to imple - ment workplace adjustments or monitor conduct going forward. The aim is to preserve privacy while ensuring that operational needs are met. 6.8 Disciplinary Measures Internal working regulation (which is mandatory for companies employing more than 70 employees and optional for employers with fewer than 70 employees) set out the available disciplinary measures. Depending on the seriousness of misconduct, these may range from warning to reprimand or suspension or fine. Any disciplinary decision must be proportionate and sup - ported by the investigation findings. In severe cases where the trust between employer and employee has been breached, although dismissal is not considered a disciplinary measure under Greek labour law, the employer may choose to proceed with immediate ter - mination of employment. Timing is important. Employers typically act without undue delay once the investigation is completed, especially where misconduct poses an ongoing risk.
However, they should also allow sufficient time to con - sider the employee’s explanation and ensure that the decision is procedurally sound. 6.9 Other Measures Many employers implement additional measures to support a healthier workplace, even when allegations are unsubstantiated. These may include refresher training, mediation between team members or steps to improve communication and supervision. In har - assment cases, employers often consider reassigning tasks or adjusting reporting lines to restore a safe envi - ronment. Such measures help reduce the likelihood of future conflicts and demonstrate a proactive approach to maintaining respectful working conditions. Data protection in Greece is regulated by the GDPR, Greek law 4624/2019 as well as any specific/secto - ral legislation, and interpreted and enforced by the Hellenic Data Protection Authority (HDPA) and the courts. The matter of data processing in HR investi - gations is not explicitly regulated (with the exception of Law 4990/2022 on Whistle-Blowing). An employer is allowed to collect personal data for the purpose of an HR investigation as long as the general obligations set by the legal framework are respected, as outlined below. Legal Basis 7. Data Protection 7.1 Collecting Personal Data The key to lawful data collection/processing is the selection of the appropriate legal basis. In most instances the legitimate interests (GDPR Article 6 (1)(f)) basis will apply. In such a case, the employer should be able to demonstrate that the processing is neces - sary and proportionate, and employees’ rights are not overridden. A Legitimate Interests Assessment (LIA) is expected or a specific analysis in the Data Protection Impact Assessment on employees. For specific matters, the legal basis of compliance with Legal obligation (GDPR Article 6 (1)(c)) would apply, when a specific law requires investigative process - ing (for example, obligations arising from Greece’s
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