What about accuracy?

Example

An employer collects office ethernet connection data to monitor the use of workspace and ensure there is sufficient capacity for workers. They should not re-use this information for performance management purposes without identifying a new lawful basis and establishing the necessity and proportionality of this new purpose.

Further reading – ICO guidance

Guide to the UK GDPR – data minimisation

You should:

• take all reasonable steps to ensure the personal data you gather through monitoring workers is not incorrect or misleading as to any matter of fact; and • provide workers with the opportunity to comment on the accuracy of any data gathered through monitoring. This particularly applies if the employer is using the data to make potentially adverse decisions about them, for example if they use monitoring data in performance reviews.

Workers have the right to request that inaccurate data is corrected.

You should consider:

• Equipment or systems malfunction can cause information collected through monitoring to be misleading or inaccurate, for example a computer system resetting to the wrong time zone. • Information can also be misinterpreted or even deliberately falsified. • Data analytic tools can make incorrect inferences about workers.

Ensure that within or alongside disciplinary or grievance procedures and performance reviews or appraisals workers can see and, if necessary, explain or challenge the results of any monitoring.

Further reading – ICO guidance

Guide to the UK GDPR – accuracy

Guide to the UK GDPR – right to rectification