How is AI used in workplace monitoring?
[page 28]AI is increasingly being used to monitor workers and its use is likely to become more widespread as its availability and affordability increases. Examples include:
Performance management: AI systems may log project outcomes, time spent on different tasks and analyse customer feedback to assess productivity, efficiency, and quality of work.
Employee monitoring software: this can log keystrokes, take screenshots, monitor website usage and track time spent on tasks or applications. It can even analyse e-mails and chats.
CCTV analysis: sometimes used in factories, warehouses, and shops, AI systems can track workers’ movements and analyse images to detect actions and behaviours.
When using AI processes, the ICO guidance says that employers should not simply have a policy or privacy notice that states it uses AI, but they should identify each separate operation and provide a lawful basis for processing in relation to that operation. They should say how and why they are going to use AI to process data.
The guidance points out that whether a system using AI is more or less risky than a system not using AI depends on the circumstances. It is something that an employer must consider before carrying out any monitoring and evidence of this should be included in the DPIA. This should include how they have considered less risky alternatives, if any, that achieve the same purpose of the processing. If any less risky alternatives were not used, the employer should give their reasons.