UK ICO Employment Practices and Data Protection: Monitoring Workers (2023)
The UK ICO's guidance for employers on monitoring workers under the UK GDPR: pick the least intrusive means and a lawful basis, do a DPIA for keystroke, biometric and other high-risk monitoring, consult workers or unions, tell workers what is monitored and why, keep covert monitoring exceptional and out of toilets and personal email, record calls and read message content only when justified, keep audio off, justify device and webcam monitoring, and give biometric clock-ins an alternative. Guidance, not law; under review after the Data (Use and Access) Act 2025.
UK ICO Employment Practices and Data Protection: Monitoring Workers (2023) is a compliance framework from United Kingdom with 4 domains and 58 controls that map to 2 other frameworks. The largest domains are Data protection and monitoring workers – UK ICO Employment Practices and Data Protection: Monitoring Workers (2023) (31 controls), Different ways or methods of monitoring workers – UK ICO Employment Practices and Data Protection: Monitoring Workers (2023) (17 controls), Biometric data for time and access control and monitoring – UK ICO Employment Practices and Data Protection: Monitoring Workers (2023) (7 controls). Every control below carries what it requires and what an assessor expects to see.
Framework summaries on this platform are AI-assisted interpretations for educational and compliance planning purposes. They do not reproduce or replace the official standards. Refer to the authoritative source for the definitive text. Framework names and trademarks belong to their respective organisations.
Framework Domains (4)
Biometric data for time and access control and monitoring – UK ICO Employment Practices and Data Protection: Monitoring Workers (2023)
| Code | Title |
|---|---|
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::4.1 | 4.1 Biometric access and time control: document why biometrics are necessary and why alternatives are inadequate, in the DPIA |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::4.2 | 4.2 Biometric access: a lawful basis and a special category condition, and a non-biometric alternative without disadvantage |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::4.3 | 4.3 Biometric identification of workers always needs a DPIA before processing, discussed with workers |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::4.4 | 4.4 Biometric systems: accuracy checks, bias mitigation, manual review of access denials without detriment |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::4.5 | 4.5 Tell workers how the biometric system works, what is collected, how it is used and why |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::4.6 | 4.6 Objection and withdrawal for biometric access: honour them and provide an alternative without detriment |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::4.7 | 4.7 Biometric security: risk-appropriate measures; templates kept only as needed, refreshed, non-reversible and stored apart |
Data protection and monitoring workers – UK ICO Employment Practices and Data Protection: Monitoring Workers (2023)
| Code | Title |
|---|---|
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.10 | 1.10 Accountability: proportionate policies, senior ownership, DPO involvement and briefed staff |
| 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 |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.12(a) | 1.12(a) Define and document the purpose; no monitoring just in case |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.12(b) | 1.12(b) Monitoring policies set out nature, purpose and extent, are brought to workers' attention, and match practice |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.12(c) | 1.12(c) Use monitoring information for a new purpose only if compatible, consented or required by law |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.13 | 1.13 Collect no more than needed and review regularly to prevent function creep |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.14 | 1.14 Accuracy: correct monitoring data, weigh challenges, and let workers see and explain results |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.15 | 1.15 Retention schedule for monitoring data, justified by business need and reviewed |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.16 | 1.16 Security of monitoring data: risk-based measures, need-to-know access, trained staff, and responsibility for processors and tools |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.17 | 1.17 Tell workers what is collected and how, keep privacy information current, and tell them of changes |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.18 | 1.18 Seek and document the views of workers or their representatives (such as trade unions) before introducing monitoring |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.19(a) | 1.19(a) Covert monitoring only exceptionally, for suspected crime or gross misconduct, authorised by senior management after a DPIA |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.19(b) | 1.19(b) Covert monitoring: tightly targeted and time-limited, never in toilets or changing rooms, and not of private communications |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.19(c) | 1.19(c) Covert monitoring: use the information only for the investigation, few people involved, disclosure rules, contracts with investigators, and SARs |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.2 | 1.2 Monitor only in line with data protection law, with a clear purpose and the least intrusive means |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.20 | 1.20 Answer subject access requests for monitoring data, and plan retrieval in the DPIA |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.21 | 1.21 Handle objections to monitoring under public task or legitimate interests, and explain refusals with complaint and court rights |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.22 | 1.22 Third-party monitoring providers: check compliance, choose a competent processor and have a contract |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.23 | 1.23 Restricted transfers of worker data need adequacy, appropriate safeguards with a transfer risk assessment, or an exception |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.3 | 1.3 Identify a lawful basis, plus a special category condition where sensitive data will or may be captured, and check other laws |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.4(a) | 1.4(a) Choose the lawful basis for the specific purpose, document it from the start and do not switch later |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.4(b) | 1.4(b) Consent is rarely valid for monitoring at work; where used it must be withdrawable without detriment and recorded |
| 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 |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.4(d) | 1.4(d) Legitimate interests: pass the purpose, necessity and balancing tests, record a legitimate interests assessment, and respect reasonable expectations |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.5(a) | 1.5(a) Identify a special category condition before monitoring that will or may capture sensitive data, keep only what is relevant |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.5(b) | 1.5(b) Explicit consent as a condition only with a genuine, penalty-free choice |
| 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 |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.6 | 1.6 Criminal offence data from monitoring needs official authority or a Schedule 1 condition |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.7 | 1.7 Check other laws beyond data protection before monitoring |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.8 | 1.8 Fairness: monitor only as workers would reasonably expect, without unjustified adverse effects |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::1.9 | 1.9 Transparency: tell workers about monitoring in an accessible way, except where covert monitoring is exceptionally justified |
Different ways or methods of monitoring workers – UK ICO Employment Practices and Data Protection: Monitoring Workers (2023)
| Code | Title |
|---|---|
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::3.1 | 3.1 Remote and home working: factor higher privacy expectations and family capture into the DPIA |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::3.10 | 3.10 Data loss prevention and traffic monitoring: least invasive means, a DPIA, and blocking with review as an alternative |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::3.11(a) | 3.11(a) Device activity monitoring: document the justification, use less intrusive means if they work, identify a basis and condition, and do a DPIA |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::3.11(b) | 3.11(b) Device activity monitoring: consider discussing it with workers or representatives and inform workers, including its use in decisions |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::3.11(c) | 3.11(c) Device activity monitoring: webcam capture rarely justified, keystroke logging is behavioural biometric data, and private use of own devices kept out |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::3.2 | 3.2 Commercial monitoring tools: settle controller and processor roles first, choose a processor with guarantees, and get enough information by contract |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::3.3(a) | 3.3(a) Call monitoring: not all calls by default, itemised records first, workers told, personal calls not routinely monitored |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::3.3(b) | 3.3(b) Call monitoring: tell callers the call is recorded and why |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::3.4(a) | 3.4(a) Email and message monitoring: a clear, necessary purpose, workers told, and a DPIA |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::3.4(b) | 3.4(b) Email and message content only exceptionally, with a clear policy and advance notice; network data first |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::3.5(a) | 3.5(a) Video monitoring of workers: DPIA, targeted at risk areas with low privacy expectations, workers and others informed, footage redactable |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::3.5(b) | 3.5(b) Audio recording off by default and used only exceptionally |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::3.5(c) | 3.5(c) Facial recognition in worker monitoring: special category data, a lawful basis and condition, and a DPIA |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::3.6 | 3.6 Vehicle monitoring: inform workers and passengers, rarely during private use, DPIA for driver behaviour or analytics |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::3.7 | 3.7 Dashcams: audio off by default, not continuous, and switchable off duty |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::3.8 | 3.8 Customer-requested monitoring: the employer decides, and must still find it necessary, proportionate and notified |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::3.9 | 3.9 Time and access records: a clear purpose and no reuse for other purposes |
Monitoring tools that use solely automated processes – UK ICO Employment Practices and Data Protection: Monitoring Workers (2023)
| Code | Title |
|---|---|
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::2.1 | 2.1 Solely automated decisions with legal or similarly significant effects on workers: only on a permitted ground, without disadvantaging those who ask for a human |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::2.2 | 2.2 Tell workers about automated decision-making, its logic and consequences; provide ways to get human intervention and challenge; check systems regularly |
| uk-ico-employment-practices-and-data-protection-monitoring-workers-2023::2.3 | 2.3 Human oversight must be meaningful, not a rubber stamp |
Maps to 2 other frameworks
Coverage is not the same as your position
This page shows what UK ICO Employment Practices and Data Protection: Monitoring Workers (2023) 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.
The Compliance Position Diagnostic, $5,000 fixed, ten business daysWhat is UK ICO Employment Practices and Data Protection: Monitoring Workers (2023) and who does it apply to?
UK ICO Employment Practices and Data Protection: Monitoring Workers (2023) is a compliance framework from United Kingdom with 4 domains and 58 controls. The UK ICO's guidance for employers on monitoring workers under the UK GDPR: pick the least intrusive means and a lawful basis, do a DPIA for keystroke, biometric and other high-risk monitoring, consult workers or unions, tell workers what is monitored and why, keep covert monitoring exceptional and out of toilets and personal email, record calls and read message content only when justified, keep audio off, justify device and webcam monitoring, and give biometric clock-ins an alternative. Guidance, not law; under review after the Data (Use and Access) Act 2025. It is used by organisations to establish and maintain compliance with industry standards and regulatory requirements.
What does UK ICO Employment Practices and Data Protection: Monitoring Workers (2023) actually require?
UK ICO Employment Practices and Data Protection: Monitoring Workers (2023) has 58 controls organised across 4 domains. The largest domains are Data protection and monitoring workers – UK ICO Employment Practices and Data Protection: Monitoring Workers (2023) (31 controls), Different ways or methods of monitoring workers – UK ICO Employment Practices and Data Protection: Monitoring Workers (2023) (17 controls), Biometric data for time and access control and monitoring – UK ICO Employment Practices and Data Protection: Monitoring Workers (2023) (7 controls). Each control defines specific requirements that organisations must implement to achieve compliance.
If I already comply with another framework, how much of UK ICO Employment Practices and Data Protection: Monitoring Workers (2023) do I already cover?
UK ICO Employment Practices and Data Protection: Monitoring Workers (2023) maps to 2 other compliance frameworks. The top mapping partners are UK GDPR (UK General Data Protection Regulation) (98% coverage), ISO 27001:2022 (2% coverage). Use our comparison tool to explore control-level mappings between frameworks.
How do I implement UK ICO Employment Practices and Data Protection: Monitoring Workers (2023)?
Start your UK ICO Employment Practices and Data Protection: Monitoring Workers (2023) compliance journey by running a self-assessment on our platform to identify your current compliance posture. Our AI advisory can answer specific questions about UK ICO Employment Practices and Data Protection: Monitoring Workers (2023) 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 58 controls and track your progress.
Start Your Compliance Journey
Create a free account to run self-assessments, get AI advisory, and track your compliance progress across 849 frameworks.
Get Started Free →Free forever — no credit card required