Employee Data Privacy

Sweden - Security Requirements

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What security obligations are imposed on data controllers and data processors? 

Security requirements may not always be included in the data protection law, but are key to guaranteeing lawful processing of personal data. The entity processing the data must take all useful precautions with respect to the nature of the data and the risk presented by the processing, to preserve the security of the data and prevent alteration, corruption or access by unauthorized third parties.

The Swedish Personal Data Act (1998) currently sets the security standards that organizations must follow. Note that this may change once Sweden updates their national laws to comply with the GDPR.

Under the Personal Data Act, employers are expected to implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk. When determining which security measures are appropriate consider:

  • the available technology,
  • the cost of implementing measures,
  • the risk to individuals, and
  • the sensitivity of the data.

Technical measures should include firewalls, encryption, anti-virus, etc. Organizational measures should include steps such as clear security policies and procedures.

HR Best Practices: : Ensure contracts with service providers detail the security and confidentiality measures that will be implemented. Note that security obligations may be updated once Sweden updates national laws to comply with the GDPR. 


Led by PeopleDoc’s Chief Legal & Compliance Officer, the HR Compliance Assist team relies on a network of internal and external compliance experts and lawyers, including the global law firm Morgan Lewis, to provide clients with best practices and recommendations on topics such as HR document retention, employee data privacy, and HR electronic records. HR Compliance Assist also provides local compliance monitoring and alert services in select countries where PeopleDoc’s customers have employees. HR Compliance Assist is a service exclusively available to PeopleDoc customers.

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