The EU Says Your Work Email Address and Signature Are Also Personal Data (L.H. v. Ministerstvo Zdravotnictví)

Can your work identity be kept private in public contracts? Explore how the EU Court redefined personal data and transparency.

Ever wondered if your name, work email address and signature on a work contract could count as personal data? The Court of Justice of the European Union (CJEU) just delivered a surprising answer in a case that pits privacy against public transparency.

🏛️ Court: Court of Justice of the European Union (CJEU), First Chamber
🗓️ Judgment Date: 3 April 2025
🗂️ Case Number: Celex 62023CJ0710, C‑710/23

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Legal Issues

📜 L.H. v. Ministerstvo Zdravotnictví case involves a privacy law suit between public transparency 🧾 and personal data protection 🔐 under the General Data Protection Regulation (GDPR) in the European Union.

Here’s the main issue:

Should the signatures, email address, and contact details of individuals who sign documents on behalf of companies, like contracts for COVID-19 tests, be kept private or disclosed to the public? Even if they’re just acting in their professional roles?

Imagine you are the director of a company and you sign a deal with the government. Later, someone requests public records related to that deal.

Should your personal details, like your full name, email address and signature, be revealed, even though it was “just business”? And if yes, should you be notified first before the government releases that info?

This case dives deep into the definition of “personal data” 🧑‍💼 and whether it still counts as private if shared in a work setting. It also questions whether national laws can go beyond the GDPR by requiring extra steps, like informing people before their data is shared, even when GDPR doesn’t mandate it.

The challenge? Balancing openness in government with the individual’s right to privacy. Should public interest in knowing “who signed what” overshadow an individual’s control over their own data?

💡 This case is important because it shapes how much personal information about professionals especially in public contracts should be available to the public in the name of transparency.

🤔 Would you be okay with your work identity being made public without your say?

📕 Material Facts

During the COVID-19 pandemic 🦠, governments rushed to secure testing kits to protect public health. In the Czech Republic 🇨🇿, the Ministry of Health signed contracts with various companies to purchase COVID-19 screening tests 🧪. These contracts included certificates confirming the tests could be used within the European Union.