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) 1.4(c): 1.4(c) Contract, legal obligation, vital interests and public task each have narrow conditions for monitoring

Contract applies only where monitoring is necessary for the employer's side of the contract, which is hard to envisage (a contract clause announcing CCTV for productivity is not enough). Legal obligation needs a common law or statutory duty (not a contractual one) that the employer can point to by provision or reliable guidance, such as drivers' hours rules requiring tachograph data, with no more collected than the duty needs. Vital interests is confined to life-or-death situations such as a test pilot's physiological monitoring. Public task needs the task to be clearly grounded in law, and cannot be used where a less intrusive way achieves the same purpose.

Maintained by Gerard Blokdyk

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  • Art.6 Article 6 Lawfulness of processing

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