GDPR questions and answers

GDPR: QUESTIONS AND ANSWERS

Category:
DPO Challenges

How can the number of sent/received emails and attachments be monitored without reviewing the content of the emails?

ANSWER

When determining the scope of email monitoring, it should always be remembered what purposes such monitoring may serve under the Labour Code – namely, ensuring work organization that enables the full use of working time and the proper use of work tools made available to employees.

Accordingly, employers must always carefully consider whether analyzing the content of employees' correspondence is actually necessary to achieve these purposes, or whether it would be sufficient to verify only the frequency of sent emails, the number of received emails, and, for example, the categories or recipients of the messages.

It is essential to recognize the distinction between monitoring the communication itself (message flow, frequency, etc.) and monitoring the content of messages. The latter is, for obvious reasons, a more intrusive measure, although it may also be permissible in justified cases.

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