How can business meetings, e.g. audits, be recorded lawfully for the purpose of preparing a report or notes? What should you pay attention to?

ANSWER

In such a situation, the employer must ensure a valid legal basis for processing data. Such a basis may be the consent of the data subject, Article 6(1)(a) GDPR.

An employer wishing to make audio or audio-video recordings of employees, e.g. during various types of business meetings, should therefore obtain the consent of all participants taking part in the conversations. The employee (meeting participant) should be able to refuse to give consent to recording the meeting. The employee may also withdraw consent given to record the meeting at any time.

An important issue is also fulfilling the information obligation towards employees, in which information concerning the processing of their data for the purpose discussed will be provided in particular.