Where the word “employee” is used in this Opinion, WP29 does not intend to restrict the scope of this term merely to persons with an employment contract recognized as such under applicable labour laws. Over the past decades, new business models served by different types of labour relationships, and in particular employment on a freelance basis, have become more commonplace. This Opinion is intended to cover all situations where there is an employment relationship, regardless of whether this relationship is based on an employment contract.
(EN) ISO/IEC 27701, adopted in 2019, added a requirement additional to ISO/IEC 27002, section 7.2.2.
Here is the relevant paragraphs to article 39(1)(b) GDPR:
6.4.2.2 Information security awareness, education and training
Implementation guidance
Measures should be put in place, including awareness of incident reporting, to ensure that relevant staff are aware of the possible consequences to the organization (e.g. legal consequences, loss of business and brand or reputational damage), to the staff member (e.g. disciplinary consequences) and to the PII principal (e.g. physical, material and emotional consequences) of breaching privacy or security rules and procedures, especially those addressing the handling of PII.
NOTE Such measures can include the use of appropriate periodic training for personnel having access to PII.