Necessity“Necessity does not mean that processing of personalinformation has to be absolutely essential in order for alawful basis to be valid. However, necessity does meanmore than just useful or desirable. You cannot arguethat processing is necessary just because you havechosen to operate your business in a certain way.” - ICO
Impact assessmentRemember – this is mandatory for “high risk” processingWhat is the purpose of the monitoring?Is the method of monitoring you are proposing necessary to achieve thatpurpose?Is there a less intrusive way to achieve the purpose?How will you be transparent with employees about the purpose of themonitoring and is this reflected in your policies and communications tostaff?
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