UK ICO Employment Practices and Data Protection: Monitoring Workers (2023)
Data protection and monitoring workers – UK ICO Employment Practices and Data Protection: Monitoring Workers (2023)

UK ICO Employment Practices and Data Protection: Monitoring Workers (2023) 1.11: 1.11 DPIA before high-risk monitoring, DPO advice recorded, workers informed before start, ICO consulted if high risk remains

A DPIA must precede any processing that probably poses high risk to workers or others, such as biometric processing, keystroke monitoring, monitoring that may cause financial loss (performance management) or profiling to decide access to services; it should also consider customers, the public and household members captured. Where there is a DPO, the employer must seek and record the DPO's independent advice before deciding; if it goes ahead it must inform workers before monitoring begins; if high risk cannot be reduced it must consult the ICO first. The ICO expects a DPIA even without high risk, or a documented decision not to do one.

Maintained by Gerard Blokdyk

What else in your programme already covers this

This control maps to 2 controls across 1 other frameworks. If you already hold one of them, the evidence you collected for it is the starting point here rather than new work.

  • Art.35 Article 35 Data protection impact assessment
  • Art.36 Article 36 Prior consultation

Every mapping shown was judged rather than inferred from wording similarity, and the ones that failed review are published too. See the coverage reports and what was rejected.

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