Policy & Documentation
Written Policies
- Employee monitoring policy exists and is up to date
- Policy clearly states what is monitored and why
- Policy explains privacy protections and employee rights
- Policy defines data retention periods
- Policy is accessible to all employees
- Policy has been reviewed by legal counsel
- Policy updated within last 12 months or as laws changed
Employee Consent & Notification
Consent Management
- All employees have been notified about monitoring practices
- Employee consent/acknowledgment obtained and documented
- Consent forms stored securely in employee files
- New employees receive monitoring policy during onboarding
- Employees reminded of monitoring practices annually
- Process in place for employees to withdraw consent (if applicable)
GDPR Compliance (If Applicable)
GDPR Requirements
- Lawful basis for processing identified and documented
- Privacy notice provided to employees (Article 13/14)
- Data minimization principles followed (only necessary data collected)
- Privacy by design implemented (screenshot blurring, encryption)
- Data retention periods defined and implemented
- Process for handling data subject access requests (DSARs)
- Process for data deletion requests
- Data processing agreements with vendors (if applicable)
- Data breach notification procedures in place
US Labor Law Compliance
State & Federal Requirements
- Compliance with state notification requirements (if applicable)
- Two-party consent requirements met (if in applicable states)
- Workplace privacy expectations respected
- No monitoring of protected activities (union organizing, etc.)
Privacy & Security
Data Protection
- Screenshot blurring enabled for sensitive data (PII)
- Data encrypted in transit (HTTPS/TLS)
- Data encrypted at rest
- Access controls restrict data to authorized personnel only
- Audit logs track all data access
- Regular security reviews conducted
- Data backup and recovery procedures in place
Monitoring Scope & Limitations
Appropriate Monitoring
- Monitoring limited to work time only (not breaks or personal time)
- Screenshot frequency appropriate for business need
- No monitoring of personal devices without clear policy
- No monitoring of protected communications or activities
- Monitoring scope documented in policy
Employee Rights
Rights Management
- Employees can access their own screenshots/data
- Process for data correction requests
- Process for data deletion requests (where legally allowed)
- Process for data export requests
- Complaint process for privacy concerns
- Response times for rights requests documented and met
Data Retention & Deletion
Retention Management
- Data retention periods defined in policy
- Retention periods comply with legal requirements
- Automated deletion after retention period
- Process for extending retention when legally required
- Secure deletion procedures verified
Training & Awareness
Staff Education
- Managers trained on compliance requirements
- HR staff trained on employee rights and processes
- IT staff trained on security and privacy controls
- Regular compliance training sessions conducted
- Training records maintained
Vendor & Third-Party Compliance
Vendor Management
- Data processing agreements with vendors (if applicable)
- Vendor security assessments conducted
- Vendor compliance with data protection requirements verified
Incident Response
Breach Preparedness
- Data breach response plan documented
- Breach notification procedures defined (72 hours for GDPR)
- Incident response team identified
- Regular breach response drills conducted
Documentation & Records
Record Keeping
- All compliance documentation organized and accessible
- Consent forms stored securely
- Audit logs maintained and reviewed regularly
- Compliance audit reports documented
Audit Schedule
Recommended audit frequency:
- Quarterly: Quick review of policy compliance and employee consent
- Annually: Comprehensive compliance audit using this checklist
- As needed: When laws change, after incidents, or when expanding to new jurisdictions
Next Steps After Audit
- Document findings and create action plan for any gaps
- Prioritize critical compliance issues
- Assign owners and deadlines for remediation
- Schedule follow-up review
- Update policies and procedures as needed
- Communicate changes to employees
Additional Resources
- Screenshot Monitoring Compliance Guide - Detailed compliance information
- Employee Monitoring Policy Template
- Frequently Asked Questions - Compliance questions
- Glossary - Key terms like GDPR, PII, etc.