PTD-Art.12: Data protection
To the extent that information provided under the transparency and reporting measures (Articles 7, 9 and 10) involves the processing of personal data, it shall be provided in accordance with Regulation (EU) 2016/679; personal data shall not be used for any purpose other than implementing the equal-pay principle, and pay information shall not lead to disclosure of an identifiable co-worker's pay other than as provided.
Our statement of the clause of Directive (EU) 2023/970 on pay transparency, held and verified: cite it as PTD-Art.12. The instrument verbatim is not quoted here; the held framework carries the reading.
The evidence this duty asks you to hold
GDPR-compliant handling of pay data used for transparency/reporting; Safeguards preventing disclosure of an identifiable co-worker's pay
What usually goes missing
Using pay data beyond the equal-pay purpose; Disclosing identifiable individual pay without basis
Where this lands in an audit
In Equal Pay Auditor this control informs the same-work screen, the category figures and the remediation steps, which carry their article citations on the result.