Employee Monitoring Law Planner
Sources

New York Labor Law sections 203-c and 203-d (recording in restrooms, locker rooms and changing rooms; personal identifying information)

Law. Placed at New York. Read 30 Sep 2026; 2 provisions cited by the planner.

What does NY Labor Law 203-c require?

An employer must not arrange or permit video capture of a worker inside a restroom, a locker room or a room set aside for staff to change clothes, unless a court order allows it. Also cited: s 203-c(2), do not use a recording made in violation of the section for any purpose.

NY Labor Law s 203-c(1)Do not cause a video recording of an employee in a restroom, locker room or changing room without a court order

An employer must not arrange or permit video capture of a worker inside a restroom, a locker room or a room set aside for staff to change clothes, unless a court order allows it. The duty is on causing the recording, so cameras installed by landlords, contractors or security vendors at the employer's request are caught, as are cameras outside the room whose field of view reaches inside.

What a reviewer asks to see: Camera register by site with field of view, confirming no coverage of restrooms, locker rooms or designated changing rooms; Photographs or plans showing camera placement at the entrances to those rooms; Court order on file for any permitted recording; Vendor instructions and acceptance tests for new camera installations
Where monitoring plans usually fall short: Camera in a corridor that sees through a locker-room door when it is open; A room used informally for changing not recognised as a designated changing room; Vendor-installed cameras not reviewed against the section
Source: New York Labor Law sections 203-c and 203-d (recording in restrooms, locker rooms and changing rooms; personal identifying information), read 30 Sep 2026
NY Labor Law s 203-c(2)Do not use a recording made in violation of the section for any purpose

A video recording made in violation of the section may not be used by the employer for any purpose, including discipline, investigation, litigation or security review. The control is a procedure that quarantines and destroys any such footage once discovered.

What a reviewer asks to see: Investigation procedure stating that footage from restrooms, locker rooms or changing rooms is never relied on; Incident log for any protected-room recording discovered: quarantine, deletion and notifications; Retention settings for security video that exclude protected rooms
Where monitoring plans usually fall short: Footage from a misplaced camera cited in a disciplinary decision; Cloud video archive retaining protected-room recordings; No procedure for discovered recordings
Source: New York Labor Law sections 203-c and 203-d (recording in restrooms, locker rooms and changing rooms; personal identifying information), read 30 Sep 2026

Open the full text on compliance.theartofservice.com

See the specimen plan run Plan your own list