The thirteen findings
In fixed order. A line appears under every finding it raises, and its stamps show each one; a finding that rests on a blank column is a question naming the column.
- 1 Representative step before start not recordedWhich works agreement, works council consent, CSE consultation, union agreement or inspectorate authorisation covers this practice at this location, and was it in place before the practice started?
- 2 Notice not recorded, or its period not metWhat notice was given for this practice here, on what date, and does it carry what the law of the place asks (the period, the content, an acknowledgement, a posting)?
- 3 Written policy not recorded where the law asks for oneWhich written policy covers this practice, and when were staff told of it?
- 4 Covert monitoringWhat authority, suspicion or ground stands behind running this without the staff knowing, and who signed it off?
- 5 Monitoring a place the law keeps privateDoes this practice watch or listen to anyone in a toilet, change room, shower, break room or other place the law of this location keeps free of it, and can it be removed or re-aimed?
- 6 Monitoring outside workDoes this practice follow people outside working time or off the premises, and what switches it off?
- 7 Call recording consentWhose consent does the law of this location ask before a call is recorded (every party, or one), how is it obtained, and does it hold for callers in other states?
- 8 Biometric dataWhich written notice, release, consent or Art. 9 condition covers each person whose fingerprint, face or hand is taken, and what is the destruction date?
- 9 AI emotion recognition in the workplaceDoes this tool infer emotion, mood or sentiment from staff (or detect presence or objects only), and is it intended for medical or safety reasons?
- 10 Continuous, keystroke or screenshot monitoring with no assessment recordedWhere is the assessment (a DPIA, or the necessity and proportionality test) that came before this practice, and what less intrusive way was considered?
- 11 Retention not set, or above the period you setHow long is this data kept, and why that long?
- 12 Personal devices monitoredWhat on the personal device is monitored, how is private use kept out, and whose consent or authorisation covers it?
- 13 Lawful basis not recorded for an EU or UK lineWhich Art. 6 basis covers this practice, or which works agreement meeting Art. 88(2), and where is it documented?