www.ico.gov.uk/upload/documents/library/data_protection/practical_application/gpn_disclosure_employee_info_tupe_v1.0.pdf

The Information Commissioner’s Office has published new guidance to help employers when transferring employees under TUPE. It is often a minefield to comply with requests for information about employees and simultaneously observe the DPA. In brief, it is recommended that in the early stages of a transaction, names and other identifying information should be left out. When employee information under Regulation 11 of TUPE is to be provided both parties should take care to comply with data protection principles and the buyer must only use the information for the purposes of TUPE.