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) 1.5(c): 1.5(c) Employment or substantial public interest conditions: identify the law and keep an appropriate policy document

The employment, social security and social protection condition can fit health, safety and welfare monitoring, but the employer must point to the specific legal duty or right (by provision or clear guidance), cannot use it for purely contractual rights, and must meet Schedule 1 Part 1, which needs an appropriate policy document. The substantial public interest condition needs a basis in law, a justification for using special category data, a Schedule 1 Part 2 condition (a bank's CCTV relying on preventing or detecting unlawful acts, for example) and in almost every case an appropriate policy document.

Maintained by Gerard Blokdyk

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  • Art.9 Article 9 Processing of special categories of personal data

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