Workplace Digital Devices, Video Surveillance and Geolocation Policy

How to use this document

• What it is for. This is a base policy for employers in Spain. It sets the criteria for using the digital devices the company provides to staff, the conditions for accessing their content and the prior information on video surveillance, geolocation and the use of AI or analytics on that data. It is designed to be prepared with the participation of worker representatives, which is the approach of arts. 87 to 90 of Organic Law 3/2018 (LOPDGDD).
• Who should own it. Human resources, with legal, the data protection officer (if any), IT and security. Enter the function in [RESPONSIBLE FUNCTION] and the person in [OWNER].
• Decisions to take first. Decide whether or not to allow private use of devices (section 5.2, options A and B), which monitoring systems you use or plan to use and for what purpose (sections 5.4, 6, 7 and 8), who may authorize access to a device's content (section 5.5) and the retention periods (section 11).
• Worker representative participation. Plan the consultation timeline before approval: presentation of the draft, period for comments or a report, and minutes of the meeting (aid D). Also check whether your collective agreement sets additional safeguards.
• Fields to complete. Replace [ORGANIZATION NAME], [LEGAL ENTITY NAME], [RESPONSIBLE FUNCTION], [PRIVACY EMAIL], [DATE] and [COMPLETE]. Keep [OPTIONAL] clauses only if they apply.
• Country variant. The document is designed for Spain. The "Country variants" section sets out the authority, terms and deadlines fixed by Spanish law. If you use it as a reference in another country, replace that variant with local law.
• Related documents. This policy does not replace the digital disconnection policy, the record of processing activities, the data protection impact assessment (DPIA) of the monitoring systems or the algorithmic information given to worker representatives; it refers to them.
• Review and publication. Have your employment and data protection advisors review the adapted version. Approve it, record the version in "Version history," communicate it to all staff and keep proof of the communication.

Workplace Digital Devices, Video Surveillance and Geolocation Policy

Field	Value
Company	[LEGAL ENTITY NAME]
Owning function	[RESPONSIBLE FUNCTION]
Policy owner	[OWNER]
Consultation with worker representatives	[DATE]; [COMPLETE: body consulted and minutes reference]
Approved by	[APPROVED BY]
Effective date	[DATE]
Review frequency	[REVIEW FREQUENCY]
Privacy contact	[PRIVACY EMAIL]

1. Purpose

In this policy, [ORGANIZATION NAME] sets the criteria for using the digital devices it provides to its staff, the safeguards it applies when accessing their content and the information on the video surveillance, geolocation and automated analysis systems it uses to monitor work, while respecting workers' privacy and dignity.

2. Scope

2.1. It applies to all workers of [ORGANIZATION NAME], including managers and remote workers and, where relevant, interns and temporary agency staff.

2.2. It covers digital devices and services provided by the company (computers, phones, tablets, email accounts, messaging, cloud storage, corporate applications and internet access), video surveillance and sound recording systems in workplaces, geolocation systems in vehicles, devices or applications, and any tool, including AI, that analyzes data from them.