CCTV (break, change or wash rooms): what the law asks at each location

What it watches

a room where staff change, wash, rest or eat

Family

Camera

Reads as this class

for example "camera in the staff change room" in a practice column

• Representative stepstatutory requirementInform and consult the CSE before deciding to put the means of control in place, while the consultation can still change the decision (undertakings of 50 or more employees). (where a CSE exists) Code du travail L2312-38 al3Code du travail L2312-8 II 4Code du travail L2312-14CNIL guidance ACT-6
• Representative stepofficial guidance, not lawThe CNIL adds, for cameras: inform and consult the staff representative bodies before any decision to install. (where a CSE exists) CNIL guidance VID-10 official guidance, not law
• Noticestatutory requirementThe Art. 13 information at the time the data is collected: who, why, on which basis, the legitimate interest where that is the basis, recipients, retention, rights. GDPR Art. 13WP249 para 3.1.2
• Noticeofficial guidance, not lawSigns before the monitored area at about eye level, making clear what is covered. EDPB video guidelines para 7.1.1 official guidance, not law
• Noticestatutory requirementNo information about an employee may be collected by a device not first brought to the employee's knowledge. Code du travail L1222-4CNIL guidance ACT-7
• Noticeofficial guidance, not lawPermanent visible signs with the purposes, retention, contact and rights. CNIL guidance VID-8 official guidance, not law
• Places kept privatestatutory requirement not allowed hereNo fixing, recording or live transmission of the image of a person in a private place (a changing room, a private office, any place not open to the public) without their consent where it is done to reach into their private life; consent is presumed only where the filming was open and the person could object. A criminal provision, read beside the CNIL pages. (where it covers toilets or washrooms, change or locker rooms and showers or bathing areas) Code penal art. 226-1 (2)Code penal art. 226-1
• Places kept privateofficial guidance, not law guidance says noNo cameras in sanitary facilities; rest areas are where people expect not to be watched. (where it covers toilets or washrooms, showers or bathing areas, change or locker rooms and break rooms or staff lounges) EDPB video guidelines para 3.1.3.2 official guidance, not law
• Places kept privateofficial guidance, not law guidance says noLimits by place: never in sensitive areas such as places of worship, sanitary facilities and break rooms. (where it covers toilets or washrooms, showers or bathing areas, change or locker rooms, break rooms or staff lounges and prayer rooms) WP249 para 3.1.1(d) official guidance, not law
• Places kept privateofficial guidance, not law guidance says noCameras do not film break or rest areas, toilets, or union and staff representative premises. (where it covers toilets or washrooms, showers or bathing areas, change or locker rooms and break rooms or staff lounges) CNIL guidance VID-3 official guidance, not law
• Personal devicesofficial guidance, not lawTell private from business use so private information is not monitored; the employer's ownership of a device does not remove the secrecy of communications. (if personal devices are monitored) WP249 para 5.4.2(a)WP249 para 6.1 official guidance, not law
• Lawful basisstatutory requirementAn Art. 6 basis for each purpose; Art. 88 lets national law or collective agreements set more specific employment rules, and is not a basis itself. Consent is rarely free at work; legitimate interest needs a necessary, least intrusive method and a documented balance. GDPR Art. 6GDPR Art. 88WP249 para 3.1.1(a)WP249 para 3.1.1(c)
• Lawful basisofficial guidance, not lawEmployers should not rely on consent for video; national law or works agreements may set employment rules. EDPB video guidelines para 3.3(b) official guidance, not law
• Lawful basisstatutory requirementEvery restriction on employees' rights justified by the task and proportionate to the aim. Code du travail L1121-1
• Assessmentofficial guidance, not lawMany video cases need an assessment, and large-scale monitoring of public areas always does. EDPB video guidelines para 10 official guidance, not law
• Retentionstatutory requirementKept no longer than the purpose needs, with a set retention period, and deleted once no longer needed. GDPR Art. 5WP249 para 3.1(d)
• Retentionofficial guidance, not lawFootage usually erased within a few days; beyond 72 hours needs stronger justification. EDPB video guidelines para 8 official guidance, not law
• Retentionofficial guidance, not lawImages in principle kept no more than one month. CNIL guidance VID-7 official guidance, not law
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Representative stepstatutory requirementA works agreement (or a conciliation committee award) before the practice starts, changes or is extended. The test is whether the device can monitor conduct or performance, not what it was bought for; a company-wide system goes to the central works council. (where a works council exists) BetrVG s 87(1) no. 6BetrVG s 80(2)BetrVG s 77(1), (2)BDSG s 26(4)
• Noticestatutory requirementThe Art. 13 information at the time the data is collected: who, why, on which basis, the legitimate interest where that is the basis, recipients, retention, rights. GDPR Art. 13WP249 para 3.1.2
• Noticeofficial guidance, not lawSigns before the monitored area at about eye level, making clear what is covered. EDPB video guidelines para 7.1.1 official guidance, not law
• Noticestatutory requirementMake the camera and the controller identifiable at the earliest point, with signs before the monitored area. BDSG s 4(2)
• Places kept privatestatutory requirement not allowed hereNo image of a person in a room specially protected against view (a changing room, toilet, treatment room or sauna) created or transmitted without authorisation where it reaches into their most personal sphere of life; the legitimate-interest exception of the section does not apply to this offence. A criminal provision, read beside the BDSG lines. (where it covers toilets or washrooms, change or locker rooms, showers or bathing areas and first-aid rooms or sick bays) StGB s 201a(1) no. 1
• Places kept privateofficial guidance, not law guidance says noNo cameras in sanitary facilities; rest areas are where people expect not to be watched. (where it covers toilets or washrooms, showers or bathing areas, change or locker rooms and break rooms or staff lounges) EDPB video guidelines para 3.1.3.2 official guidance, not law
• Places kept privateofficial guidance, not law guidance says noLimits by place: never in sensitive areas such as places of worship, sanitary facilities and break rooms. (where it covers toilets or washrooms, showers or bathing areas, change or locker rooms, break rooms or staff lounges and prayer rooms) WP249 para 3.1.1(d) official guidance, not law
• Limitsstatutory requirementVideo of publicly accessible spaces only as needed for a listed purpose. BDSG s 4(1)
• Covert monitoringstatutory requirementTo uncover a crime: documented factual indications supporting a suspicion of an offence in the employment relationship, the processing necessary to uncover it, and not disproportionate to the occasion. BDSG s 26(1) sentence 2
• Personal devicesofficial guidance, not lawTell private from business use so private information is not monitored; the employer's ownership of a device does not remove the secrecy of communications. (if personal devices are monitored) WP249 para 5.4.2(a)WP249 para 6.1 official guidance, not law
• Lawful basisstatutory requirementAn Art. 6 basis for each purpose; Art. 88 lets national law or collective agreements set more specific employment rules, and is not a basis itself. Consent is rarely free at work; legitimate interest needs a necessary, least intrusive method and a documented balance. GDPR Art. 6GDPR Art. 88WP249 para 3.1.1(a)WP249 para 3.1.1(c)
• Lawful basisofficial guidance, not lawEmployers should not rely on consent for video; national law or works agreements may set employment rules. EDPB video guidelines para 3.3(b) official guidance, not law
• Lawful basisstatutory requirementEmployee data only where necessary for the employment relationship; consent only where genuinely voluntary, in writing or electronically, with notice of the right to withdraw. BDSG s 26(1) sentence 1BDSG s 26(2)
• Assessmentofficial guidance, not lawMany video cases need an assessment, and large-scale monitoring of public areas always does. EDPB video guidelines para 10 official guidance, not law
• Retentionstatutory requirementKept no longer than the purpose needs, with a set retention period, and deleted once no longer needed. GDPR Art. 5WP249 para 3.1(d)
• Retentionofficial guidance, not lawFootage usually erased within a few days; beyond 72 hours needs stronger justification. EDPB video guidelines para 8 official guidance, not law
• Retentionstatutory requirementVideo data deleted without delay once no longer needed. BDSG s 4(5)
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Representative stepstatutory requirementEquipment that also allows remote monitoring of workers only for organisational and production needs, workplace safety or asset protection, and only after an agreement with the union representation or, failing one, prior authorisation from the labour inspectorate. Workers' Statute Art. 4(1)Italian Privacy Code Art. 114Italian Privacy Code Art. 171
• Noticestatutory requirementThe Art. 13 information at the time the data is collected: who, why, on which basis, the legitimate interest where that is the basis, recipients, retention, rights. GDPR Art. 13WP249 para 3.1.2
• Noticeofficial guidance, not lawSigns before the monitored area at about eye level, making clear what is covered. EDPB video guidelines para 7.1.1 official guidance, not law
• Noticestatutory requirementAdequate information to workers on how the instruments are used and how checks are made, before the data is used for any employment purpose. Workers' Statute Art. 4(3)
• Places kept privateofficial guidance, not law guidance says noNo cameras in sanitary facilities; rest areas are where people expect not to be watched. (where it covers toilets or washrooms, showers or bathing areas, change or locker rooms and break rooms or staff lounges) EDPB video guidelines para 3.1.3.2 official guidance, not law
• Places kept privateofficial guidance, not law guidance says noLimits by place: never in sensitive areas such as places of worship, sanitary facilities and break rooms. (where it covers toilets or washrooms, showers or bathing areas, change or locker rooms, break rooms or staff lounges and prayer rooms) WP249 para 3.1.1(d) official guidance, not law
• Personal devicesofficial guidance, not lawTell private from business use so private information is not monitored; the employer's ownership of a device does not remove the secrecy of communications. (if personal devices are monitored) WP249 para 5.4.2(a)WP249 para 6.1 official guidance, not law
• Lawful basisstatutory requirementAn Art. 6 basis for each purpose; Art. 88 lets national law or collective agreements set more specific employment rules, and is not a basis itself. Consent is rarely free at work; legitimate interest needs a necessary, least intrusive method and a documented balance. GDPR Art. 6GDPR Art. 88WP249 para 3.1.1(a)WP249 para 3.1.1(c)
• Lawful basisofficial guidance, not lawEmployers should not rely on consent for video; national law or works agreements may set employment rules. EDPB video guidelines para 3.3(b) official guidance, not law
• Assessmentofficial guidance, not lawMany video cases need an assessment, and large-scale monitoring of public areas always does. EDPB video guidelines para 10 official guidance, not law
• Retentionstatutory requirementKept no longer than the purpose needs, with a set retention period, and deleted once no longer needed. GDPR Art. 5WP249 para 3.1(d)
• Retentionofficial guidance, not lawFootage usually erased within a few days; beyond 72 hours needs stronger justification. EDPB video guidelines para 8 official guidance, not law
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Representative stepstatutory requirementThe works council's consent to the arrangement before it is adopted: a proposal in writing with reasons and consequences, at least one consultation meeting, then written notice of the decision and its start date. Without consent or the cantonal court's permission the decision is void if the council invokes nullity. (where a works council exists) WOR Art. 27(1)(l)WOR Art. 27(2)WOR Art. 27(4)
• Noticestatutory requirementThe Art. 13 information at the time the data is collected: who, why, on which basis, the legitimate interest where that is the basis, recipients, retention, rights. GDPR Art. 13WP249 para 3.1.2
• Noticeofficial guidance, not lawSigns before the monitored area at about eye level, making clear what is covered. EDPB video guidelines para 7.1.1 official guidance, not law
• Places kept privateofficial guidance, not law guidance says noNo cameras in sanitary facilities; rest areas are where people expect not to be watched. (where it covers toilets or washrooms, showers or bathing areas, change or locker rooms and break rooms or staff lounges) EDPB video guidelines para 3.1.3.2 official guidance, not law
• Places kept privateofficial guidance, not law guidance says noLimits by place: never in sensitive areas such as places of worship, sanitary facilities and break rooms. (where it covers toilets or washrooms, showers or bathing areas, change or locker rooms, break rooms or staff lounges and prayer rooms) WP249 para 3.1.1(d) official guidance, not law
• Personal devicesofficial guidance, not lawTell private from business use so private information is not monitored; the employer's ownership of a device does not remove the secrecy of communications. (if personal devices are monitored) WP249 para 5.4.2(a)WP249 para 6.1 official guidance, not law
• Lawful basisstatutory requirementAn Art. 6 basis for each purpose; Art. 88 lets national law or collective agreements set more specific employment rules, and is not a basis itself. Consent is rarely free at work; legitimate interest needs a necessary, least intrusive method and a documented balance. GDPR Art. 6GDPR Art. 88WP249 para 3.1.1(a)WP249 para 3.1.1(c)
• Lawful basisofficial guidance, not lawEmployers should not rely on consent for video; national law or works agreements may set employment rules. EDPB video guidelines para 3.3(b) official guidance, not law
• Assessmentofficial guidance, not lawMany video cases need an assessment, and large-scale monitoring of public areas always does. EDPB video guidelines para 10 official guidance, not law
• Retentionstatutory requirementKept no longer than the purpose needs, with a set retention period, and deleted once no longer needed. GDPR Art. 5WP249 para 3.1(d)
• Retentionofficial guidance, not lawFootage usually erased within a few days; beyond 72 hours needs stronger justification. EDPB video guidelines para 8 official guidance, not law
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Noticestatutory requirementThe Art. 13 information at the time the data is collected: who, why, on which basis, the legitimate interest where that is the basis, recipients, retention, rights. GDPR Art. 13WP249 para 3.1.2
• Noticeofficial guidance, not lawSigns before the monitored area at about eye level, making clear what is covered. EDPB video guidelines para 7.1.1 official guidance, not law
• Noticestatutory requirementInform workers, and their representatives where there are any, beforehand and expressly, clearly and concisely, before camera images are used to control workers; sound recording only where the activity carries relevant security risks. LOPDGDD Art. 89
• Places kept privatestatutory requirement not allowed hereNo sound recording or video surveillance in places for workers' rest or leisure, such as changing rooms, toilets and canteens. (where it covers toilets or washrooms, change or locker rooms, showers or bathing areas and break rooms or staff lounges) LOPDGDD Art. 89
• Places kept privateofficial guidance, not law guidance says noNo cameras in sanitary facilities; rest areas are where people expect not to be watched. (where it covers toilets or washrooms, showers or bathing areas, change or locker rooms and break rooms or staff lounges) EDPB video guidelines para 3.1.3.2 official guidance, not law
• Places kept privateofficial guidance, not law guidance says noLimits by place: never in sensitive areas such as places of worship, sanitary facilities and break rooms. (where it covers toilets or washrooms, showers or bathing areas, change or locker rooms, break rooms or staff lounges and prayer rooms) WP249 para 3.1.1(d) official guidance, not law
• Personal devicesofficial guidance, not lawTell private from business use so private information is not monitored; the employer's ownership of a device does not remove the secrecy of communications. (if personal devices are monitored) WP249 para 5.4.2(a)WP249 para 6.1 official guidance, not law
• Lawful basisstatutory requirementAn Art. 6 basis for each purpose; Art. 88 lets national law or collective agreements set more specific employment rules, and is not a basis itself. Consent is rarely free at work; legitimate interest needs a necessary, least intrusive method and a documented balance. GDPR Art. 6GDPR Art. 88WP249 para 3.1.1(a)WP249 para 3.1.1(c)
• Lawful basisofficial guidance, not lawEmployers should not rely on consent for video; national law or works agreements may set employment rules. EDPB video guidelines para 3.3(b) official guidance, not law
• Assessmentofficial guidance, not lawMany video cases need an assessment, and large-scale monitoring of public areas always does. EDPB video guidelines para 10 official guidance, not law
• Retentionstatutory requirementKept no longer than the purpose needs, with a set retention period, and deleted once no longer needed. GDPR Art. 5WP249 para 3.1(d)
• Retentionofficial guidance, not lawFootage usually erased within a few days; beyond 72 hours needs stronger justification. EDPB video guidelines para 8 official guidance, not law
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Noticestatutory requirementThe Art. 13 information at the time the data is collected: who, why, on which basis, the legitimate interest where that is the basis, recipients, retention, rights. GDPR Art. 13WP249 para 3.1.2
• Noticeofficial guidance, not lawSigns before the monitored area at about eye level, making clear what is covered. EDPB video guidelines para 7.1.1 official guidance, not law
• Places kept privateofficial guidance, not law guidance says noNo cameras in sanitary facilities; rest areas are where people expect not to be watched. (where it covers toilets or washrooms, showers or bathing areas, change or locker rooms and break rooms or staff lounges) EDPB video guidelines para 3.1.3.2 official guidance, not law
• Places kept privateofficial guidance, not law guidance says noLimits by place: never in sensitive areas such as places of worship, sanitary facilities and break rooms. (where it covers toilets or washrooms, showers or bathing areas, change or locker rooms, break rooms or staff lounges and prayer rooms) WP249 para 3.1.1(d) official guidance, not law
• Personal devicesofficial guidance, not lawTell private from business use so private information is not monitored; the employer's ownership of a device does not remove the secrecy of communications. (if personal devices are monitored) WP249 para 5.4.2(a)WP249 para 6.1 official guidance, not law
• Lawful basisstatutory requirementAn Art. 6 basis for each purpose; Art. 88 lets national law or collective agreements set more specific employment rules, and is not a basis itself. Consent is rarely free at work; legitimate interest needs a necessary, least intrusive method and a documented balance. GDPR Art. 6GDPR Art. 88WP249 para 3.1.1(a)WP249 para 3.1.1(c)
• Lawful basisofficial guidance, not lawEmployers should not rely on consent for video; national law or works agreements may set employment rules. EDPB video guidelines para 3.3(b) official guidance, not law
• Assessmentofficial guidance, not lawMany video cases need an assessment, and large-scale monitoring of public areas always does. EDPB video guidelines para 10 official guidance, not law
• Retentionstatutory requirementKept no longer than the purpose needs, with a set retention period, and deleted once no longer needed. GDPR Art. 5WP249 para 3.1(d)
• Retentionofficial guidance, not lawFootage usually erased within a few days; beyond 72 hours needs stronger justification. EDPB video guidelines para 8 official guidance, not law
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Noticestatutory requirementThe Art. 13 information at collection, and tell workers about monitoring in an accessible way. UK GDPR Art. 13ICO monitoring guidance para 1.9
• Noticeofficial guidance, not lawSigns before the field of view, readable and sized for the setting, naming the operator, purpose and a contact. ICO video guidance P.4 official guidance, not law
• Written policyofficial guidance, not lawMonitoring policies that set out the nature, purpose and extent of monitoring, brought to workers' attention and matching what happens. ICO monitoring guidance para 1.12(b) official guidance, not law
• Places kept privateofficial guidance, not law guidance says noToilets and changing rooms only in the most exceptional circumstances. (where it covers toilets or washrooms, change or locker rooms and showers or bathing areas) ICO video guidance P.3 official guidance, not law
• Limitsofficial guidance, not lawTargeted at risk areas with low privacy expectations, workers and others informed, an assessment first. ICO monitoring guidance para 3.5(a)ICO video guidance A.4 official guidance, not law
• Covert monitoringofficial guidance, not lawCovert monitoring only exceptionally, for suspected crime or gross misconduct, authorised by senior management after an assessment, tightly targeted and time-limited, never in toilets or changing rooms. ICO monitoring guidance para 1.19(a)ICO monitoring guidance para 1.19(b) Human Rights Act, Article 8, named, not quoted official guidance, not law
• Personal devicesofficial guidance, not lawWhen workers use their own devices, make sure private use is not captured. (if personal devices are monitored) ICO monitoring guidance para 3.11(c) Human Rights Act, Article 8, named, not quoted official guidance, not law
• Lawful basisstatutory requirementAn Art. 6 basis chosen for the specific purpose and documented from the start; consent rarely valid; legitimate interests with a recorded assessment. UK GDPR Art. 6ICO monitoring guidance para 1.4(a)ICO monitoring guidance para 1.4(b)ICO monitoring guidance para 1.4(d)
• Retentionstatutory requirementA retention schedule justified by business need, reviewed, and not kept in case a use turns up. UK GDPR Art. 5ICO monitoring guidance para 1.15
• Retentionofficial guidance, not lawThe shortest period the purpose needs, never the recorder's default. ICO video guidance P.11 official guidance, not law
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Noticestatutory requirementNotify individuals of the collection and the APP 5 matters. (when you say the Privacy Act applies) APP 5
• Retentionstatutory requirementDestroy or de-identify personal information no longer needed. (when you say the Privacy Act applies) APP 11
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Noticestatutory requirementWritten notice to each employee at least 14 days before the surveillance starts (email counts), saying the kind, how it is done, when it starts, whether continuous or intermittent, and whether for a set period or ongoing. A new starter gets it before they start. NSW WSA s 10
• Noticestatutory requirementCameras clearly visible, and signs at every entrance to the place under surveillance. NSW WSA s 11
• Noticestatutory requirementNotify individuals of the collection and the APP 5 matters. (when you say the Privacy Act applies) APP 5
• Places kept privatestatutory requirement not allowed hereNo surveillance of employees in a change room, toilet, shower or other bathing facility at a workplace. (where it covers toilets or washrooms, change or locker rooms and showers or bathing areas) NSW WSA s 15
• Covert monitoringstatutory requirementNo covert surveillance of employees at work without a covert surveillance authority from a Magistrate; surveillance without the notice Part 2 asks for is covert. NSW WSA s 19NSW WSA s 22
• Covert monitoringverification requiredNo communication, publication or possession of records obtained by a device used outside the conditions of the Act, save the exceptions the Act lists: to a party to the conversation or activity, with the consent of all principal parties, to investigate or prosecute an offence under the Act, and the minimum reasonably needed where serious violence, substantial property damage or a serious narcotics offence is imminent. NSW SDA s 11NSW SDA s 12NSW SDA s 14
• Outside workstatutory requirement not allowed hereNo surveillance with a work surveillance device while the employee is not at work, except computer surveillance of the use of equipment or resources the employer provided or paid for. (if it runs outside work) NSW WSA s 16
• Personal devicesstatutory requirementTracking a person, or monitoring a computer they own, needs their consent; the employer's own devices rest on its possession or control. (if personal devices are monitored) NSW SDA s 9NSW SDA s 10
• Personal devicesstatutory requirementA camera in an employee's home or belongings needs the owner's or occupier's consent. (if personal devices are monitored) NSW SDA s 8
• Retentionstatutory requirementDestroy or de-identify personal information no longer needed. (when you say the Privacy Act applies) APP 11
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Noticestatutory requirementNotify individuals of the collection and the APP 5 matters. (when you say the Privacy Act applies) APP 5
• Places kept privatestatutory requirement not allowed hereNo camera or listening device in workplace toilets, washrooms, change rooms or lactation rooms, whether or not the workers consent. (where it covers toilets or washrooms, change or locker rooms, showers or bathing areas and lactation, nursing or parent rooms) Vic SDA s 9B
• Retentionstatutory requirementDestroy or de-identify personal information no longer needed. (when you say the Privacy Act applies) APP 11
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Representative stepstatutory requirementConsult the workers in good faith about how the surveillance will be run, for at least the 14-day notice period. ACT WPA s 14
• Noticestatutory requirementWritten notice at least 14 days before the start, giving the device, the method, who is watched, the start date, continuous or intermittent, set period or open-ended, the uses of the records, and the right to be consulted. ACT WPA s 13
• Noticestatutory requirementThe camera plainly visible and a sign at every entrance. ACT WPA s 15
• Noticestatutory requirementNotify individuals of the collection and the APP 5 matters. (when you say the Privacy Act applies) APP 5
• Places kept privatestatutory requirement not allowed hereNo surveillance in a toilet, change room, shower or bathing facility, parent or nursing room, prayer room, sick bay or first-aid room. (where it covers toilets or washrooms, change or locker rooms, showers or bathing areas, lactation, nursing or parent rooms, prayer rooms and first-aid rooms or sick bays) ACT WPA s 41
• Covert monitoringstatutory requirementNo covert surveillance of a worker without a covert surveillance authority from the Magistrates Court. ACT WPA s 35
• Outside workstatutory requirement not allowed hereNo surveillance of a worker who is not in a workplace, except data surveillance of employer-supplied equipment and tracking that cannot be switched off. (if it runs outside work) ACT WPA s 42
• Retentionstatutory requirementDestroy or permanently de-identify records no longer needed for a purpose the Act allows. ACT WPA s 44(2)
• Retentionstatutory requirementDestroy or de-identify personal information no longer needed. (when you say the Privacy Act applies) APP 11
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Noticestatutory requirementNotify individuals of the collection and the APP 5 matters. (when you say the Privacy Act applies) APP 5
• Retentionstatutory requirementDestroy or de-identify personal information no longer needed. (when you say the Privacy Act applies) APP 11
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Personal devicesstatutory requirementAn employer can authorise access to messages on a service it provides; that does not reach an employee's personal webmail or accounts, which need the user's authorisation. (if personal devices are monitored) SCA 2701(a)SCA 2701(c)(1)SCA 2701(c)(2)
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Noticestatutory requirementSecurity video sits outside the Penal Law surveillance offences only where a prominent written notice on the premises says video surveillance is installed for security, or the devices are fitted so that anyone sees them at once. NY Penal Law s 250.65
• Places kept privatestatutory requirement not allowed hereNo video recording of an employee in a restroom, locker room or room set aside for changing clothes unless a court order allows it; a camera outside the room whose field of view reaches inside is caught, and footage made against the section is not used for any purpose. (where it covers toilets or washrooms, change or locker rooms and showers or bathing areas) NY Labor Law s 203-c(1)NY Labor Law s 203-c(2)
• Places kept privatestatutory requirement not allowed hereNo imaging device installed or used to covertly view, broadcast or record a person in a changing room, fitting room, restroom, toilet, bathroom, washroom or shower, or a person dressing or undressing, without their knowledge or agreement, with a rebuttable presumption that the device had no legitimate purpose. (where it covers toilets or washrooms, change or locker rooms and showers or bathing areas) NY Penal Law s 250.45(3)NY Penal Law s 250.45
• Personal devicesstatutory requirementAn employer can authorise access to messages on a service it provides; that does not reach an employee's personal webmail or accounts, which need the user's authorisation. (if personal devices are monitored) SCA 2701(a)SCA 2701(c)(1)SCA 2701(c)(2)
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Noticestatutory requirementPrior written notice to every employee who may be affected, naming the types of monitoring and the specific locations on the premises where it may occur, posted conspicuously including at those locations; and a plain-language statement to each new hire before they start. (the replacement text takes effect 1 October 2026 (Public Act 26-73); before that date it is not in force) Conn. Gen. Stat. 31-48d(b)(1)Conn. Gen. Stat. 31-48d(b)(1)Conn. Gen. Stat. 31-48d(b)(1)Conn. Gen. Stat. 31-48d(b)(3)
• Places kept privatestatutory requirement not allowed hereNo electronic surveillance device or system, sound recording or CCTV included, to record or monitor employees in areas for their health or personal comfort or for safeguarding their possessions, such as rest rooms, locker rooms or lounges. (where it covers toilets or washrooms, change or locker rooms, showers or bathing areas and break rooms or staff lounges) Conn. Gen. Stat. 31-48b(b)
• Covert monitoringstatutory requirementMonitoring without prior written notice only on reasonable grounds to believe employees are breaking the law or others' rights, or creating a hostile workplace, where monitoring may produce evidence. (the replacement text takes effect 1 October 2026 (Public Act 26-73); before that date it is not in force) Conn. Gen. Stat. 31-48d(b)(2)
• Personal devicesstatutory requirementAn employer can authorise access to messages on a service it provides; that does not reach an employee's personal webmail or accounts, which need the user's authorisation. (if personal devices are monitored) SCA 2701(a)SCA 2701(c)(1)SCA 2701(c)(2)
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Personal devicesstatutory requirementAn employer can authorise access to messages on a service it provides; that does not reach an employee's personal webmail or accounts, which need the user's authorisation. (if personal devices are monitored) SCA 2701(a)SCA 2701(c)(1)SCA 2701(c)(2)
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Noticestatutory requirementAt or before collection, tell staff the categories collected, the purposes, and how long each is kept. (when you say the business meets the CCPA thresholds) CCPA 1798.100(a)CCPA CCR 7012
• Places kept privatestatutory requirement not allowed hereNo audio or video recording of an employee in a restroom, locker room or room set aside for changing clothes unless a court order allows it; the duty is on causing the recording, so a camera or microphone a contractor, landlord or security vendor installed at the employer's request is reached too, and a recording made against the section is not used for any purpose. (where it covers toilets or washrooms, change or locker rooms and showers or bathing areas) Cal. Lab. Code s 435(a)Cal. Lab. Code s 435(b)
• Places kept privatestatutory requirementFrom the day Part 5.8 takes effect: no workplace surveillance tool of any kind (video, audio, location, badge logging, wearables, time tracking) monitors employees in a workplace bathroom, save a court order and one-time entry and exit checks; employees may leave a tool they carry outside the room, and a badge or alarm they must carry captures no audio or video and carries no embedded AI. (where it covers toilets or washrooms and showers or bathing areas) Cal. Lab. Code s 1560Cal. Lab. Code s 1560
• Personal devicesstatutory requirementAn employer can authorise access to messages on a service it provides; that does not reach an employee's personal webmail or accounts, which need the user's authorisation. (if personal devices are monitored) SCA 2701(a)SCA 2701(c)(1)SCA 2701(c)(2)
• Retentionstatutory requirementRetention periods disclosed and no longer than reasonably necessary. (when you say the business meets the CCPA thresholds) CCPA 1798.100(a)
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Personal devicesstatutory requirementAn employer can authorise access to messages on a service it provides; that does not reach an employee's personal webmail or accounts, which need the user's authorisation. (if personal devices are monitored) SCA 2701(a)SCA 2701(c)(1)SCA 2701(c)(2)
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Personal devicesstatutory requirementAn employer can authorise access to messages on a service it provides; that does not reach an employee's personal webmail or accounts, which need the user's authorisation. (if personal devices are monitored) SCA 2701(a)SCA 2701(c)(1)SCA 2701(c)(2)
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Personal devicesstatutory requirementAn employer can authorise access to messages on a service it provides; that does not reach an employee's personal webmail or accounts, which need the user's authorisation. (if personal devices are monitored) SCA 2701(a)SCA 2701(c)(1)SCA 2701(c)(2)
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Personal devicesstatutory requirementAn employer can authorise access to messages on a service it provides; that does not reach an employee's personal webmail or accounts, which need the user's authorisation. (if personal devices are monitored) SCA 2701(a)SCA 2701(c)(1)SCA 2701(c)(2)
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Personal devicesstatutory requirementAn employer can authorise access to messages on a service it provides; that does not reach an employee's personal webmail or accounts, which need the user's authorisation. (if personal devices are monitored) SCA 2701(a)SCA 2701(c)(1)SCA 2701(c)(2)
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Places kept privatestatutory requirement not allowed hereNo device observing, recording or eavesdropping in a private place without the consent of those entitled to privacy there. (where it covers toilets or washrooms, change or locker rooms, showers or bathing areas and lactation, nursing or parent rooms) MCL 539d(1)(a)
• Personal devicesstatutory requirementAn employer can authorise access to messages on a service it provides; that does not reach an employee's personal webmail or accounts, which need the user's authorisation. (if personal devices are monitored) SCA 2701(a)SCA 2701(c)(1)SCA 2701(c)(2)
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Personal devicesstatutory requirementAn employer can authorise access to messages on a service it provides; that does not reach an employee's personal webmail or accounts, which need the user's authorisation. (if personal devices are monitored) SCA 2701(a)SCA 2701(c)(1)SCA 2701(c)(2)
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Personal devicesstatutory requirementAn employer can authorise access to messages on a service it provides; that does not reach an employee's personal webmail or accounts, which need the user's authorisation. (if personal devices are monitored) SCA 2701(a)SCA 2701(c)(1)SCA 2701(c)(2)
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Personal devicesstatutory requirementAn employer can authorise access to messages on a service it provides; that does not reach an employee's personal webmail or accounts, which need the user's authorisation. (if personal devices are monitored) SCA 2701(a)SCA 2701(c)(1)SCA 2701(c)(2)
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Personal devicesstatutory requirementAn employer can authorise access to messages on a service it provides; that does not reach an employee's personal webmail or accounts, which need the user's authorisation. (if personal devices are monitored) SCA 2701(a)SCA 2701(c)(1)SCA 2701(c)(2)
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Personal devicesstatutory requirementAn employer can authorise access to messages on a service it provides; that does not reach an employee's personal webmail or accounts, which need the user's authorisation. (if personal devices are monitored) SCA 2701(a)SCA 2701(c)(1)SCA 2701(c)(2)
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Personal devicesstatutory requirementAn employer can authorise access to messages on a service it provides; that does not reach an employee's personal webmail or accounts, which need the user's authorisation. (if personal devices are monitored) SCA 2701(a)SCA 2701(c)(1)SCA 2701(c)(2)
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• Noticestatutory requirementA copy of the written policy to every employee within 30 days of the date the policy was required, and to each new employee within 30 days of starting. (when you say 25 or more employees in Ontario on 1 January) Ontario ESA 41.1.1(3)Ontario ESA 41.1.1(4)
• Written policystatutory requirementA written electronic monitoring policy covering all employees, in place before 1 March, saying whether the employer monitors, how and in what circumstances, the purposes, and the dates it was prepared and changed; kept for three years after it ends. (when you say 25 or more employees in Ontario on 1 January) Ontario ESA 41.1.1(1)Ontario ESA 41.1.1(2) para 1Ontario ESA 41.1.1(2) para 1 iOntario ESA 41.1.1(2) para 1 iiOntario ESA 15(8.2)
• Retentionofficial guidance, not lawKept only as long as the purpose justifies. ILO code para 8.5 official guidance, not law

• 1 Representative step before start not recorded
• 2 Notice not recorded, or its period not met
• 3 Written policy not recorded where the law asks for one
• 4 Covert monitoring
• 5 Monitoring a place the law keeps private
• 6 Monitoring outside work
• 10 Continuous, keystroke or screenshot monitoring with no assessment recorded
• 11 Retention not set, or above the period you set
• 12 Personal devices monitored
• 13 Lawful basis not recorded for an EU or UK line

The example "camera in the staff change room" in a practice column reads as this class. Words are matched whole.

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