QQuestions:
Must government agencies obtain consent of their staff to upload the staff's photos to the intranet to be accessed and reviewed by the Chiefs and Personnel Executives?
AReply

In general, the staff's superiors and the officers responsible for managing the data have the authority to access and review the data. While photos are staff's personal data, letting the superiors with authority to access them via the intranet is but a new method of accessing. However, care should be taken to prevent the data from being improperly accessed and used.

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