1. Return-to-work bonus and the processing of personal data
A few months ago, the Programme Act of 26 December 2022 introduced Article 110/1 into the aforementioned Law on health insurance. This new provision, which came into force on 1 April 2023, allows companies that hire an incapacitated employee for a return to work authorised by the health insurance provider's physician, and who will employ them for at least 3 months, to apply for a return-to-work bonus of €1,000 paid by the health insurance provider.
As part of the bonus application, certain employer and employee personal data will have to be sent to the insurance provider. The recently adopted legislative proposal therefore aims to supplement Article 110/1 in this respect, by specifying the categories of personal data to be communicated at the time of the application, the purpose for which the data will be processed, how long the data will be kept, and who will be responsible for processing the data, in accordance with the General Data Protection Regulation (GDPR).
The legislative proposal provides for the retroactive entry into force of these provisions from 1 April 2023, to coincide with the entry into force of the aforementioned Programme Act of 26 December 2022.