Employee Monitoring: Cameras, GPS, and Company Email

How to establish the purpose, implement monitoring, and inform employees.

Status checked: November 2, 2026. We are not a law firm. The material is informational and educational in nature and does not constitute individual legal advice. Before implementing solutions, check current regulations and consult a specialist regarding your specific situation.

Monitoring is not arbitrary observation

The Labor Code provides specific rules for video monitoring, email, and other forms of monitoring. The employer should determine the actual need and purpose, assess the scope of data, and consider whether a less intrusive measure may suffice. Cameras, GPS, and email monitoring should not be treated as identical tools with a single automatic justification.

Cameras on company premises

The Labor Code lists purposes for video monitoring, such as employee safety and property protection. There are restrictions regarding specific rooms and privacy protection. The Personal Data Protection Office (UODO) indicates the necessity of clearly marking the monitored area no later than the day before activation. Monitoring recordings should not be used for arbitrary supervision unrelated to the intended purpose.

Information for employees

The purposes, scope, and manner of monitoring are established in accordance with relevant regulations, including in agreements, regulations, or announcements, depending on the employer's situation. The Labor Code requires informing employees about the introduction of monitoring at least two weeks in advance and providing relevant information to new employees before they are allowed to work.

Recordings, GPS, and email

For recordings from video monitoring, the Labor Code stipulates a processing period not exceeding three months from the recording, with exceptions for material that serves as evidence. This does not automatically mean that every recording must be kept for three months. Email monitoring and other forms must not violate the confidentiality of correspondence or other personal rights; GPS requires separate analysis of purpose and proportionality.

Example for a fleet

A company wants to track the location of company cars to organize routes. It should describe what data is collected, when, who sees it, and how long it is needed. Using a car outside of working hours may raise additional privacy questions; the specific model should be assessed before implementation.

Questions before choosing a provider

Ask the system provider for a description of the devices, the scope of information collected, service access, storage duration, and data processing locations. Check if the system allows for access restrictions based on roles and deletion of data after a specified time. The provider may be a data processor; do not assume its role without analyzing actual activities and the contract.

In the event of an incident, determine who secures the material and who can decide on its disclosure. Transferring a recording to an authority or another person requires a separate assessment of the basis and scope. Reporting a person whose data is involved should not reach an uncontrolled group of employees.

Action list

1. Define the purpose and area of observation; check alternatives.
2. Prepare rules and information for employees and signage.
3. Limit access and storage time; plan for data deletion.
4. Check cameras, GPS, and email separately, as well as the provider's documentation.

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