How do you organise a Workplace Christmas Party…

(Updated Dec 2025)

As the festive season approaches, workplace Christmas parties offer a chance to celebrate and strengthen team bonds. Some may see this guidance as unnecessary or even overkill, but a little care now will save you considerable money and many hours of stress later.

Most employment disputes, insurance claims, ICO complaints and data rows stem from avoidable mistakes made at events like these. You are the custodian of your staff’s personal data, and that includes photographs taken on the night and any later use on social media.

Respecting that responsibility is far cheaper and far easier than defending yourself when something goes wrong..

Plan the event properly

Start with the basics. Decide who is organising it, what information you need from staff and who you will be sharing that information with. Under the Data Use and Access Act 2025 you must keep an accountability log. This is where you record decisions about what staff data you are collecting, why you need it, who will see it and how long you will keep it. It applies even to something as simple as a Christmas party, because you are still handling personal data.

If you are collecting dietary requirements, accessibility needs or menu choices, keep this as simple as possible. Dietary requirements can reveal religious beliefs or health conditions, so they count as special category data. Only collect what you need for the meal, share it only with the venue and delete it once the event has passed.

Sharing information with the venue

Most venues will ask for an attendee list, menu choices and any special needs. Before you hand anything over, check that the venue handles data properly. This is required under Article 28 of the UK GDPR and Section 14 of the DUAA.

You need to know where the data is stored, whether it is passed to anyone else and whether any processing takes place outside the UK. Do not assume this is all in order. Ask the questions and record the answers in your accountability log.

If you are sharing sensitive data such as allergies or medical needs, keep the list short and secure. Do not email it around the office or leave it sitting on a shared drive.

Photographs and social media

Christmas parties are famous for two things: bad jumpers and even worse photos.If photos will be taken, tell staff beforehand. Your lawful basis will usually be legitimate interests, but only if you have properly assessed that interest, told people what you are doing, and given anyone who objects a clear way to opt out.

If the photos will be used anywhere beyond the internal staff newsletter, for example on LinkedIn, your website or any external promotional material, get their explicit consent. No shortcuts. the DUAA 2025 strengthens accountability, so keep a record of who agreed, what they agreed to, and where the photos will appear.

And if someone says no, respect it.

Photographs of clients and others – an often overlooked risk

It's not just employees whose data requires protection - clients and other guests attending the event must also be considered. When entertaining clients at the company Christmas party, any photos or videos featuring them are equally subject to DUAA, GDPR and the Data Protection Act. Sharing such images without obtaining their explicit consent could not only breach data protection laws but also harm professional relationships. Businesses should ensure that all attendees, including clients, are aware of and agree to any potential use of their images.

Do not assume everyone is happy to be photographed. Do not assume everyone wants their face on social media. Respect objections and keep a record of them.

Do you need a DPIA?

If you are collecting dietary data, sharing attendance lists with a venue, taking photographs or handling anything that goes beyond everyday processing you will need a Data Protection Impact Assessment. This is required under Article 35 of the UK GDPR and Section 19 of the DUAA. The DPIA shows that you have identified risks and taken reasonable steps to manage them.

On the night

Staff should enjoy themselves, but they are still representing the organisation. Alcohol has a habit of lowering inhibitions and raising problems. Remind everyone, politely, that respect for colleagues still applies and that inappropriate behaviour will be dealt with in line with your normal policies. You are not trying to kill the mood. You are protecting your staff and your organisation.

Make sure senior staff set the tone. If managers get carried away, you cannot reasonably expect others to exercise restraint.

After the event

It's important to remember that once an image is posted online, it can be challenging to remove it entirely. Even if no issues arise immediately, unforeseen problems could emerge in the future. Therefore, exercising caution and obtaining proper consent is essential to prevent potential complications (and considerable expense) down the line.

Delete any personal data you collected for the event unless you have a lawful reason to keep it. This includes menu choices, dietary information, accessibility needs and attendance lists. If any issues arise after the event, deal with them fairly and in line with your disciplinary policy.

Make sure your employee privacy notice covers event planning so staff know what data is collected and why. This is a requirement under both the UK GDPR and the DUAA.

And finally...

While Company Christmas parties are a time for celebration, it's essential to remain vigilant about Personal Data Protection. By securing explicit consent before sharing photos on social media and implementing comprehensive policies, employers can uphold their legal obligations and maintain a respectful and secure environment for all employees.

A Christmas party should be enjoyable, not an administrative headache. A bit of forward planning, a compliant approach to staff data and a reminder that everyone is still at work, even with a glass in hand, will keep it that way.

With these thoughts in mind, we wish you a joyful event, a peaceful and happy Christmas, and a prosperous 2026 for you and your colleagues

If you need help reviewing your policies or preparing for the DUAA, feel free to ask.

Warmest greetings from all of us at Hebborn Consultancy Ltd.

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