How should we balance our obligations under the pay transparency rules with the GDPR principles of data minimisation and personal data protection?

The application of the Directive’s requirements does not exclude the obligation to process personal data in accordance with the GDPR / Regulation (EU) 2016/679. We expect the transposition of the Directive to provide a specific mechanism enabling employers to respond in situations where there is a risk of disclosing personal data, including the individual remuneration of one or more employees.