Telling workers
[page 38]If an employer wants to monitor its workers, they should speak to staff. Failure to do this will breach one of the core data protection principles of “lawfulness, fairness and transparency”.
The ICO guidance says that employers must make sure workers are aware of what personal information they are collecting and how they are doing it. They should have a system in place that reminds workers it is taking place, such as on the intranet or by putting up signs. They should tell workers if they make changes.
Employers should also ensure that workers can see the results of any monitoring and have it explained to them, and to challenge the results. This can be done as part of disciplinary or grievance procedures, performance reviews or appraisals, or separately.