In February 2025, a GDPR code of conduct was presented by the Sectoral Training Fund for Temporary Work (Fonds de Formation Sectoriel pour l’Intérim - FSI), in collaboration with FEDIL Employment Services (F.E.S.).
A GDPR code of conduct is a voluntary sector-specific compliance tool that contributes to the proper application of the GDPR, taking into account the operational needs of the sector concerned, in this case the temporary work sector in Luxembourg.
This is the very first GDPR code of conduct applicable in the Grand Duchy of Luxembourg to have been approved by the CNPD.
How the Code Came About
This GDPR Code of Conduct was drawn up by the temporary work sector in Luxembourg to support the implementation of the GDPR, taking into account the sector’s specific tripartite employment relationship. The Sectoral Training Fund for Temporary Work (FSI), which represents all temporary work agencies in Luxembourg, led this initiative due to the compulsory membership of temporary work agencies and its independent status.
The FSI organised meetings with the temporary work agencies to discuss data protection practices, resulting in a Code that reflects the consensus of the majority of temporary work agencies in Luxembourg, covering more than half of the temporary work market.
Objectives of the Code
The objectives of this GDPR Code of Conduct are as follows:
- GDPR Guide: to harmonise practices across medium-sized enterprises of all sizes, to clarify the data collected and transmitted, and the retention periods, with practical measures and forms
- Transparency: to ensure the transparent and secure management of personal data, thereby building trust;
- Implementation practices: to describe the stages of the process, from a candidate’s registration to the management of their career.
Implementation of the Code
The Code includes controls to assess member companies’ handling of personal data, with specific metrics. The proper implementation of the Code is overseen by a monitoring body, in accordance with Chapter 5, ‘Supervision, Compliance and Monitoring Body’ (« Surveillance, conformité et organisme de suivi »).
The monitoring body for the Code is ESCEM a.s.b.l., which has been accredited by the CNPD. The CNPD, for its part, is the supervisory authority for the Code.