Hello, my name is***** am a qualified lawyer and I will be assisting you with your question today. So to clarify when you share this data, what exactly would be visible to the employees you are discussing it with?
Items such as speeding violations/ harsh breaking occurences. This information is being discussed in order to prevent any serious accidents from happening. The top 10 best drivers has been shared in a Health and Safety bulletin however I'm note sure I am in agree with publishing names to the rest of the business.
The main issues here would be to do with data protection and that includes any personal information about an individual. In order to qualify it must be data from which a person can be personally identified. So a name would likely be sufficient to amount to that. Once you have personal data in your possession you need to ensure that it is processed fairly. For example, one of the principles you must adhere to is that data is processed for the reason it was initially obtained so if you had not obtained the data to share it with others, rather it was just collected for your own requirements, it may be going beyond what you are allowed to do if you were to share it. I would therefore suggest that unless you have the person's specific consent (whether they are at the top or the bottom of the list), you should not share the identifiable elements, such as names or any other information from which the individual can be identified. Sharing generic data about driving styles, incidents, etc is fine but just keep it to this, without naming individuals, unless you have their specific consent to do so.
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