Can an employer who is not obliged to create work regulations simply mark the rooms covered by monitoring with graphic signs?

One of our Clients, who intends to introduce not only video surveillance but also other forms of monitoring in his workplace, asked us for an opinion on whether he has any other obligations related to the introduction of this monitoring apart from marking the rooms and informing his employees about it.

The Client is a so-called “small employer”, employing fewer than 50 workers, and therefore not obliged to develop and apply work regulations, and there are no trade unions operating there either.

The Law Firm’s attorneys conducted an analysis of the factual and legal status and informed the client that the above-mentioned obligations are not all and only ones that must be fulfilled, because according to art. 22² § 6 of the Labor Code, an employer who is not covered by a collective labor agreement or is not obliged to establish work regulations should set out the objectives, scope and manner of application of monitoring.

Furthermore, the Law Firm’s lawyers prepared a customized notice for the Client that specified not only the purposes but also the detailed scope and methods of the monitoring being used.

The Client implemented video surveillance in permissible areas of the workplace, as well as on the company parking lot. Additionally, as the employer provides company cars to employees, they decided to introduce GPS tracking.

We also prepared a complete set of documents that the employer is legally required to provide to employees, regardless of the notice about the monitoring.