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Directive 970/23 on pay transparency and data protection: a necessary balancing act
September 30, 2025
Alveriapress
Directive 970/23 on pay transparency and data protection: a necessary balancing act
La Directive (EU) 970/23 introduces stringent obligations regarding pay transparencywith the aim of reduce the gender pay gap and strengthening the right to equal treatment. Among the main innovations is the workers' right to receive information on average wage levels, broken down by genderfor categories of workers doing the same work or work of equal value (Article 7), and theobligation for employers with at least 100 employees to prepare periodic equal pay reports (Article 9).
However, these obligations raise important questions in relation to the framework of the personal data protectiongoverned by the Regulation (EU) 2016/679 (GDPR). In fact, the disclosure of salary data can lead to identifiability risksespecially in corporate contexts of small size or in the highly specialised roles. In such cases, the combination of variables (role, department, gender, seniority) could make individual workers recognisable, potentially conflicting with the principles of minimisation (Art. 5(1)(c) GDPR) and purpose limitation (Art. 5(1)(b)).
The Directive itself recognises the need for balance: theArticle 19 specifies in fact that transparency obligations must be implemented "respecting the right to the protection of personal data as laid down in Regulation (EU) 2016/679".. This implies a twofold commitment for employers: guarantee workers' right to information and, at the same time, apply appropriate protective measures to prevent the undue dissemination of identifiable data.
Practical measures include:
-
Anonymisation or pseudonymisation of salary datasets;
-
Minimum numerosity thresholds in reports, avoiding publications where the group is too small;
-
Aggregation by salary range rather than timely disclosure;
-
Data governance policy defining roles and responsibilities in information management.
In this context, the cooperation between HR and Data Protection Officer is decisive: the former must ensure the proper implementation of the principles of fairness and transparency, the latter must ensure that reporting methods comply with the principles of the GDPR, for instance by applying impact assessments (DPIA, Art. 35 GDPR) in the most delicate cases.
La Directive 970/23read in parallel with the GDPRoffers a framework that can foster not only the gender equalitybut also a more solid culture of organisational responsibilityin which the individual and collective rights are protected in a synergetic manner.
The challenge is therefore to finding a new balance point. In this process, it is crucial that organisations have a always up-to-date, consistent and reliable data set and that they equip themselves with a system capable of flexibly managing the balance between the need for transparency and the protection of privacy.
In this perspective, Alveria can support companies by providing a platform integrating secure data collection, advanced analysis tools and GDPR-compliant governance mechanismsallowing transforming regulatory obligations into an opportunity for transparency, equity and organisational empowerment.
Article published by
CONSULTANCY, TRAINING, HR DIGITALIZATION AND CORPORATE SOLUTIONS, DISCOVER THE ALVERIA METHOD. GET READY FOR CHANGE.
La Directive (EU) 970/23 introduces stringent obligations regarding pay transparencywith the aim of reduce the gender pay gap and strengthening the right to equal treatment. Among the main innovations is the workers' right to receive information on average wage levels, broken down by genderfor categories of workers doing the same work or work of equal value (Article 7), and theobligation for employers with at least 100 employees to prepare periodic equal pay reports (Article 9).
However, these obligations raise important questions in relation to the framework of the personal data protectiongoverned by the Regulation (EU) 2016/679 (GDPR). In fact, the disclosure of salary data can lead to identifiability risksespecially in corporate contexts of small size or in the highly specialised roles. In such cases, the combination of variables (role, department, gender, seniority) could make individual workers recognisable, potentially conflicting with the principles of minimisation (Art. 5(1)(c) GDPR) and purpose limitation (Art. 5(1)(b)).
The Directive itself recognises the need for balance: theArticle 19 specifies in fact that transparency obligations must be implemented "respecting the right to the protection of personal data as laid down in Regulation (EU) 2016/679".. This implies a twofold commitment for employers: guarantee workers' right to information and, at the same time, apply appropriate protective measures to prevent the undue dissemination of identifiable data.
Practical measures include:
-
Anonymisation or pseudonymisation of salary datasets;
-
Minimum numerosity thresholds in reports, avoiding publications where the group is too small;
-
Aggregation by salary range rather than timely disclosure;
-
Data governance policy defining roles and responsibilities in information management.
In this context, the cooperation between HR and Data Protection Officer is decisive: the former must ensure the proper implementation of the principles of fairness and transparency, the latter must ensure that reporting methods comply with the principles of the GDPR, for instance by applying impact assessments (DPIA, Art. 35 GDPR) in the most delicate cases.
La Directive 970/23read in parallel with the GDPRoffers a framework that can foster not only the gender equalitybut also a more solid culture of organisational responsibilityin which the individual and collective rights are protected in a synergetic manner.
The challenge is therefore to finding a new balance point. In this process, it is crucial that organisations have a always up-to-date, consistent and reliable data set and that they equip themselves with a system capable of flexibly managing the balance between the need for transparency and the protection of privacy.
In this perspective, Alveria can support companies by providing a platform integrating secure data collection, advanced analysis tools and GDPR-compliant governance mechanismsallowing transforming regulatory obligations into an opportunity for transparency, equity and organisational empowerment.
Article published by
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CONSULTANCY, TRAINING, HR DIGITALIZATION AND CORPORATE SOLUTIONS, DISCOVER THE ALVERIA METHOD. GET READY FOR CHANGE.