The former employer of those involved received an e-mail regarding an invoice that had to be paid to obtain an additional pension. Since the employment contract had already ended, the former employer asked the individuals to contact the supplemental pension insurer to understand the reason for issuing the invoice.

The insurance company states that it was not informed of the end of the employment contract between the individuals and his former employer and therefore issued a new invoice. In this regard, data subjects believe that their personal data should not have been disclosed since the Respondent is not an insurance broker or policyholder.

The question at hand is whether the personal data of those involved could be disclosed to the insurance company by his employer. This question was handled by the Belgian Data Protection Authority.