Can information about monitoring be included for an employee during employment in the employee privacy policy?
ANSWER
Taking into account the requirements of both the Labour Code and the GDPR, the following is recommended to properly inform an employee about monitoring:
- familiarise the employee with the work regulations containing the monitoring rules;
- state the purpose, scope and manner of the monitoring in a separate notice, in accordance with Article 222(6) of the Labour Code;
- present the information clause in accordance with Article 13 GDPR (which may form part of the privacy policy, depending on the specific solutions adopted by your organisation);
- mark the premises and monitored area and/or the monitored work tools, which may be combined with the first layer of the information obligation under Article 13 GDPR.
