GDPR places a much higher threshold on controllers that rely on consent as a basis for processing personal data. It will be dependent on our clients to determine the purpose and means of processing and to ensure it provides instruction on the lawful processing of personal data it sends to Intrro. For your employees that refuse to allow their personal data to be processed or withdraw their consent and you have no other lawful reason to process their data, we can try and offer alternative ways to use our services. This way, employees have a genuine choice without jeopardizing their ability to realize the value of their awards. For data which Intrro receives directly from your employees, Intrro has updated its Privacy Policy which can be found here.