CNIL on monitoring employee software / internet use

24.10.2019

Use of video recording of screens, coupled with recordings of telephone conversations in a professional setting, may be proportionate if used only for staff training

AND:

  • you inform the employee
  • the video recording is limited to the window (s) of the business application to which the training relates;
  • the device is active only during a phone call
  • people who have a real need for training on a business application or software
  • the volume of records is proportionate to the need for training
  • employees are trained only on the basis of their own video recordings unless the other video recordings are anonymized;
  • access to the recordings is limited to authorized persons only and access traceability (logging device) is put in place
  • all the specific guarantees applicable to the recording of telephone conversations must be implemented (for example, a dedicated telephone line for staff representatives).

External link: https://www.cnil.fr/fr/lenregistrement-video-ou-la-capture-decran-couple-lenregistrement-des-conversations-telephoniques

What is the INPLP?

INPLP is a not-for-profit international network of qualified professionals providing expert counsel on legal and compliance issues relating to data privacy and associated matters. INPLP provides targeted and concise guidance, multi-jurisdictional views and practical information to address the ever-increasing and intensifying field of data protection challenges. INPLP fulfils its mission by sharing know-how, conducting joint research into data processing practices and engaging proactively in international cooperation in both the private and public sectors.