PI responds to DBT's employee monitoring technology consultation

Privacy International (PI) has submitted its response to a Department for Business and Trade (DBT) consultation on whether employers should face a new duty to consult trade unions or elected staff representatives before adopting workplace monitoring technologies (WMTs).

In its submission, PI highlighted deficiencies in data minimisation and purpose limitation principles, warning of mission creep where safety tools are repurposed for disciplinary measures. PI called for an explicit ban on selling or sharing employee data beyond its original purpose, including following corporate closure or bankruptcy. It also argued that anonymisation and aggregation offer limited protection, as even anonymous information can reinforce workplace power imbalances.

In addition, PI highlighted the need for stricter transparency in automated decision-making (ADM), noting that personalised explanations of algorithmic outcomes are essential for human oversight and appeal processes. Citing its own research on artificial intelligence (AI) recruitment, remote working software, and gig platforms, PI also called for anti-retaliation safeguards. It concluded that meaningful engagement requires mandatory consultation and negotiation before WMTs are introduced, employee involvement in impact assessments, access to sandboxes, APIs, and source code.

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