Who in the company can see employee data?
Short answer
Only those who need it for their job. This is called the "need to know" principle, and it needs to be implemented through access rights, not just declared.
On this page
1.Default access: the HR function
The HR function sees the whole employee file, and accounting sees the part it needs for payroll. Everyone else gets only a part.
The direct manager sees what their task needs: working hours, the leave schedule, appraisal results. Health data, salary amount, bailiff letters or marital status are not on this list.
If a manager needs broader information once, it is provided separately and logged — that is not grounds for standing access.
2.IT sees systems, not content
Administrator rights are not grounds for reading employee files. Technical ability to access and the right to view are two different things.
The practical rule: the administrator manages the system, not the data in it. Their actions are logged, and access to content is allowed only for a specific task and with the manager's knowledge.
| Role | What they see | What they don't see |
|---|---|---|
| HR function | The whole personnel file | Client data, if not needed |
| Accounting | Payroll, deductions, certificates | Appraisals, disciplinary records |
| Direct manager | Working hours, leave, appraisal | Health data, salary, personal documents |
| IT administrator | Systems, access rights, logs | File content without a specific task |
| Other employees | Work contact details | Any part of the personnel file |
3.Access is checked at system level, not document level
Checks happen where the data actually sits: in the application, the shared drive and the database. A written procedure changes nothing without the permissions actually set in the system.
The most common reality is a shared folder that all of administration can access, even though the procedure says only two people can. During a check, what the system shows is what counts.
4.The access list is reviewed when a role changes
The most common gap: a person changed roles and kept the old access. After a few years, a group of employees who can see everything builds up — one nobody deliberately created.
So the access review is tied to an event, not a calendar: a role change, a departure, a new system going live. Each time, the same three questions get answered.
Three questions when checking access
- Who has access to the personnel file system today?
- What specific task does each of them need it for?
- When was access last reviewed after the last role change?
Official legal text
We do not paraphrase the regulation's provisions here. The official Lithuanian text of the GDPR is available in one place and is more precise than any summary.
GDPR text in Lithuanian (EUR-Lex)