Note: employee as vulnerable person

from wp248 rev.01 (adopted)
[Guidelines on Data Protection Impact Assessment (DPIA) and determining whether
processing is “likely to result in a high risk” for the purposes of Regulation 2016/679]

page 10:

“Data concerning vulnerable data subjects (recital 75): the processing of this type of data is a criterion because of the increased power imbalance between the data subjects and the data controller, meaning the individuals may be unable to easily consent to, or oppose, the processing of their data, or exercise their rights. Vulnerable data subjects may include children (they can be considered as not able to knowingly and thoughtfully oppose or consent to the processing of their data), employees , more vulnerable segments of the population requiring special protection (mentally ill persons, asylum seekers, or the elderly, patients, etc.), and in any case where an imbalance in the relationship between the position of the data subject and the controller can be identified.”