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CNIL Guidance on Employee Monitoring and Workplace Video Surveillance

France
vcnil.fr fiches as published on 30 September 2026 (control of activity 9 July 2026; access and time control updated 17 June 2026; video 23 July 2018; geolocation 30 May 2023; screen capture 17 September 2019; internet and email 20 November 2015; telework Q&A 12 November 2020; call recording and telephone use 5 May 2009, flagged under revision)
10 domains
52 controls

The French data protection authority's guidance on monitoring staff: any control device must be justified and proportionate, presented to the works council beforehand and disclosed to staff; no constant surveillance, hidden purposes or keyloggers; where cameras may and may not point, one-month retention and signage; no biometric or photo time clocks; limits on vehicle tracking outside working hours; call recording, screen capture, email and telework monitoring limits. Official guidance, not law.

Verified

CNIL Guidance on Employee Monitoring and Workplace Video Surveillance is a compliance framework from France with 10 domains and 52 controls that map to 2 other frameworks. The largest domains are Workplace video surveillance – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance (10 controls), Access to premises, time clocks and biometrics – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance (8 controls), General conditions for any activity-control device – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance (8 controls). Every control below carries what it requires and what an assessor expects to see.

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Framework Domains (10)

Absent or departing employee's mailbox – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance

2 controls
Controls in the Absent or departing employee's mailbox – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance domain of CNIL Guidance on Employee Monitoring and Workplace Video Surveillance — 2 controls
CodeTitle
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::MBX-1MBX-1 Set in advance, in the IT charter, the rules for consulting an absent employee's mailbox
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::MBX-2MBX-2 On departure, warn the employee of the account closure date and then delete the nominative address

Access to premises, time clocks and biometrics – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance

8 controls
Controls in the Access to premises, time clocks and biometrics – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance domain of CNIL Guidance on Employee Monitoring and Workplace Video Surveillance — 8 controls
CodeTitle
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::ACC-1ACC-1 Do not use biometric or photo-taking time clocks to control working hours
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::ACC-2ACC-2 Do not reuse access-control logs for another purpose such as checking hours
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::ACC-3ACC-3 Do not track movements inside the premises or check staff representatives' movements and delegation hours
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::ACC-4ACC-4 Restrict access to access and time data to authorised staff with habilitations, traceability and strong authentication
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::ACC-5ACC-5 Keep identification data for the authorisation period, access logs three months and time-tracking data up to five years
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::ACC-6ACC-6 Inform the representative bodies and give each employee clear information on the access or time system
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::ACC-7ACC-7 Record the device in the record of processing and carry out a DPIA where risk is high, notably for biometrics
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::ACC-8ACC-8 Use biometric access control only as a subsidiary measure, justified, with the template held on an individual medium

General conditions for any activity-control device – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance

8 controls
Controls in the General conditions for any activity-control device – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance domain of CNIL Guidance on Employee Monitoring and Workplace Video Surveillance — 8 controls
CodeTitle
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::ACT-1ACT-1 Define the objective and scope of each control device and identify the risks to employees' rights before installing it
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::ACT-2ACT-2 Show the device is necessary: no less intrusive means, only the data, retention and access strictly required
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::ACT-3ACT-3 Do not place staff under constant or permanent surveillance
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::ACT-4ACT-4 Do not use a device for a hidden purpose other than the one declared
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::ACT-5ACT-5 Keystroke loggers are disproportionate for monitoring staff
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::ACT-6ACT-6 Submit the device to the staff representative bodies before implementation
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::ACT-7ACT-7 Inform the people concerned before the device is put in place
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::ACT-8ACT-8 Document the compliance analysis and re-check each device before any installation or change

Internet, email and IT tools – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance

5 controls
Controls in the Internet, email and IT tools – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance domain of CNIL Guidance on Employee Monitoring and Workplace Video Surveillance — 5 controls
CodeTitle
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::NET-1NET-1 Set and communicate the tolerated personal use of IT tools and control internet and email use only for security and abuse
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::NET-2NET-2 Do not receive automatic copies of all staff email, and keep connection logs no more than six months
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::NET-3NET-3 Respect messages and files identified as personal
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::NET-4NET-4 Keep passwords confidential and demand them only when an absent employee's post holds indispensable information
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::NET-5NET-5 Consult the representative bodies, inform staff through a charter, record the processing and involve the DPO

Listening to and recording calls – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance

6 controls
Controls in the Listening to and recording calls – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance domain of CNIL Guidance on Employee Monitoring and Workplace Video Surveillance — 6 controls
CodeTitle
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::CALL-1CALL-1 Listen to or record calls only occasionally, for training, evaluation, service quality or legally provided proof, collecting only what is needed
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::CALL-2CALL-2 Do not record calls permanently or systematically unless a law requires it
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::CALL-3CALL-3 Provide lines or a cut-off for personal calls and for staff representatives
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::CALL-4CALL-4 Limit access to recordings to the service pursuing the purpose, with authorisations and traceability
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::CALL-5CALL-5 Keep recordings up to six months and analysis documents up to one year
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::CALL-6CALL-6 Consult the representative bodies and inform employees and callers, including the periods when employees may be recorded

Monitoring teleworkers – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance

3 controls
Controls in the Monitoring teleworkers – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance domain of CNIL Guidance on Employee Monitoring and Workplace Video Surveillance — 3 controls
CodeTitle
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::TLW-1TLW-1 Do not monitor teleworkers constantly by webcam, audio, screen sharing, keyloggers or forced presence checks
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::TLW-2TLW-2 Do not impose cameras on in videoconferences unless background blur is available or the meeting requires it
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::TLW-3TLW-3 Enter teleworker monitoring in the record of processing and run a DPIA for any constant monitoring

Screen capture and screen video coupled with call recording – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance

2 controls
Controls in the Screen capture and screen video coupled with call recording – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance domain of CNIL Guidance on Employee Monitoring and Workplace Video Surveillance — 2 controls
CodeTitle
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::SCR-1SCR-1 Do not couple screen captures with call recording
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::SCR-2SCR-2 Couple screen video with call recording only for training, with every listed safeguard

Telephone usage records – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance

1 controls
Controls in the Telephone usage records – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance domain of CNIL Guidance on Employee Monitoring and Workplace Video Surveillance — 1 controls
CodeTitle
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::PHN-1PHN-1 Mask the last four digits on call records, keep telephony data a year at most and never monitor representatives' calls

Vehicle geolocation and telematics – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance

7 controls
Controls in the Vehicle geolocation and telematics – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance domain of CNIL Guidance on Employee Monitoring and Workplace Video Surveillance — 7 controls
CodeTitle
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::GEO-1GEO-1 Use vehicle geolocation only for the purposes the CNIL recognises
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::GEO-2GEO-2 Do not use geolocation to check speed, to monitor continuously, for free-roaming staff, staff representatives or outside working time
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::GEO-3GEO-3 Let employees switch off location collection outside working time
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::GEO-4GEO-4 Restrict geolocation data to authorised staff and do not give clients the driver's name
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::GEO-5GEO-5 Secure the geolocation platform and bind its provider by contract
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::GEO-6GEO-6 Keep location data two months, one year for route optimisation or proof, five years for working time
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::GEO-7GEO-7 Inform or consult the representative bodies and inform each driver before installing geolocation

Workplace video surveillance – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance

10 controls
Controls in the Workplace video surveillance – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance domain of CNIL Guidance on Employee Monitoring and Workplace Video Surveillance — 10 controls
CodeTitle
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::VID-1VID-1 Install cameras only for a defined, lawful and legitimate purpose
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::VID-10VID-10 Inform and consult the staff representative bodies before deciding to install cameras
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::VID-2VID-2 Point cameras at entrances, exits, emergency exits, circulation routes and storage areas, not at workstations
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::VID-3VID-3 Do not film break or rest areas, toilets, or union and staff representative premises
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::VID-4VID-4 Secure remote viewing and do not use it to supervise work quality
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::VID-5VID-5 Record sound only in particular situations, triggered by an employee
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::VID-6VID-6 Limit viewing of images to authorised, trained persons and secure access
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::VID-7VID-7 Set a retention period tied to the purpose, in principle not over one month, and log extractions
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::VID-8VID-8 Post permanent visible signs with the required information and give full information by other means
cnil-guidance-on-employee-monitoring-and-workplace-video-surveillance::VID-9VID-9 Complete the formalities: register entry, DPO involvement, DPIA where required, prefectoral authorisation for areas open to the public

Maps to 2 other frameworks

52 total controls
GDPR
46 source controls mapped|14 target controls covered
88%
ISO 27001:2022
5 source controls mapped|4 target controls covered
10%

Coverage is not the same as your position

This page shows what CNIL Guidance on Employee Monitoring and Workplace Video Surveillance overlaps with in general. Where your organisation actually stands, against the standard you are going for and the certifications you already hold, is a different question. Same graph and the same recorded refutations, scoped to you rather than to a pair.

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What is CNIL Guidance on Employee Monitoring and Workplace Video Surveillance and who does it apply to?

CNIL Guidance on Employee Monitoring and Workplace Video Surveillance is a compliance framework from France with 10 domains and 52 controls. The French data protection authority's guidance on monitoring staff: any control device must be justified and proportionate, presented to the works council beforehand and disclosed to staff; no constant surveillance, hidden purposes or keyloggers; where cameras may and may not point, one-month retention and signage; no biometric or photo time clocks; limits on vehicle tracking outside working hours; call recording, screen capture, email and telework monitoring limits. Official guidance, not law. It is used by organisations to establish and maintain compliance with industry standards and regulatory requirements.

What does CNIL Guidance on Employee Monitoring and Workplace Video Surveillance actually require?

CNIL Guidance on Employee Monitoring and Workplace Video Surveillance has 52 controls organised across 10 domains. The largest domains are Workplace video surveillance – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance (10 controls), Access to premises, time clocks and biometrics – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance (8 controls), General conditions for any activity-control device – CNIL Guidance on Employee Monitoring and Workplace Video Surveillance (8 controls). Each control defines specific requirements that organisations must implement to achieve compliance.

If I already comply with another framework, how much of CNIL Guidance on Employee Monitoring and Workplace Video Surveillance do I already cover?

CNIL Guidance on Employee Monitoring and Workplace Video Surveillance maps to 2 other compliance frameworks. The top mapping partners are GDPR (88% coverage), ISO 27001:2022 (10% coverage). Use our comparison tool to explore control-level mappings between frameworks.

How do I implement CNIL Guidance on Employee Monitoring and Workplace Video Surveillance?

Start your CNIL Guidance on Employee Monitoring and Workplace Video Surveillance compliance journey by running a self-assessment on our platform to identify your current compliance posture. Our AI advisory can answer specific questions about CNIL Guidance on Employee Monitoring and Workplace Video Surveillance requirements, and cross-framework mapping helps you leverage existing controls from other frameworks you may already comply with. Create a free account to access all 52 controls and track your progress.

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