GV010Worker representative engagement

The involvement of the body representing the workforce in the design of the program, as distinct from any instrument deployed under it.

Pillar: GV | Governance and mandate
Sources cited: 10
Added: 30 AUGUST 2026
Updated: 20 SEPTEMBER 2026

Control	Jurisdiction	Source	What it establishes	Prerequisite or recommendation
GV010/ATMandatory	Austria	Arbeitsverfassungsgesetz, sections 96 and 96aNationalrat · read 29 Aug 2026	That a control measure touching human dignity has no legal effect without the works council’s consent, and that consent for automated processing and for assessment systems can be replaced by a conciliation board while consent under section 96 cannot.	The works council does not consent to a control measure as a step before it, but as the condition of its legal effect. What brings a measure inside the requirement is whether it touches human dignity.
GV010/BEMandatory	Belgium	Convention collective de travail n° 81 du 26 avril 2002Conseil national du Travail · read 29 Aug 2026	Four purposes for which network communication data may be monitored, collection in the aggregate rather than by name, and individualization as a separate operation with conditions of its own.	The works council is informed on every aspect of the monitoring before the system is installed, and failing a works council the prevention committee, then the union delegation, then the workers.
GV010/FIMandatory	Finland	Laki yksityisyyden suojasta työelämässä (759/2004)Parliament of Finland · read 29 Aug 2026	One act for the whole subject, holding processing to what is directly necessary, naming the conditions for cameras and for opening the employer’s electronic mail, and putting technical monitoring through a cooperation procedure before it is introduced.	Camera surveillance, access control, other technical monitoring, and the use of electronic mail and the network go through the cooperation procedure before the employer decides. Where the cooperation acts do not apply, the employees or their representatives are heard first.
GV010/FRMandatory	France	Code du travail, articles L1121-1, L1222-4, and L2312-38République française · read 16 Aug 2026	Consultation of the social and economic committee before the decision, prior knowledge for the worker, and proportionality to the task.	The body brought in is the social and economic committee, informed and consulted before the decision, and informed again before automated personnel management processing is introduced.
GV010/DEMandatory	Germany	Betriebsverfassungsgesetz, section 87(1)(6)Bundestag · read 16 Aug 2026	Co-determination by the works council over the introduction and the use of technical devices intended to monitor conduct or performance.	The body brought in is the works council, and its role is co-determination rather than consultation: the employer cannot proceed over its objection.
GV010/ITMandatory	Italy	Legge 20 maggio 1970, n. 300, article 4Parliament of Italy · read 11 Aug 2026	That an instrument from which remote monitoring may follow is permitted only for stated purposes, and only after a union agreement or an authorization.	The body brought in is the union representation, and its agreement is the condition on which any instrument capable of remote monitoring may exist at all.
GV010/NLMandatory	Netherlands	Wet op de ondernemingsraden, article 27(1)(l)Staten-Generaal · read 16 Aug 2026	Consent of the works council for an arrangement directed at or merely suitable for observing presence, conduct, or performance.	The body brought in is the works council, and its consent is required for the arrangement itself, not only for the instrument under it.
GV010/NOMandatory	Norway	Arbeidsmiljøloven, sections 9-1 and 9-2Storting · read 29 Aug 2026	That a control measure needs objective grounds in the undertaking and must not be a disproportionate burden, and that it is discussed with the elected representatives, notified with its expected duration, and evaluated with them at intervals.	The need for the measure, its design, its implementation, and any material change to it are discussed with the elected representatives as early as possible.
GV010/PLMandatory	Poland	Kodeks pracy, article 22(2)Sejm of the Republic of Poland · read 20 Sep 2026	That image recording at work is open for four purposes only, one of them keeping secret information whose disclosure could harm the employer, that its purposes, scope and manner are fixed in the collective agreement, the work regulations or an announcement, that it is notified two weeks before it starts and handed to each worker before they are admitted to work, and that recordings are kept three months.	Rooms made available to the workplace trade union organisation are outside the reach of image recording. Monitoring a sanitary room requires the prior consent of that organisation or, where none operates at the employer, of employee representatives chosen in the manner that employer adopts. What is required there is consent, not consultation, and it is obtained before the monitoring starts.
Recommended	United Kingdomwhere written	Employment practices and data protection: monitoring workersInformation Commissioner's Office · read 30 Aug 2026	What the British regulator expects of an employer that watches its workers, told apart as what an employer must do and what it should, and the conditions it sets on watching them without telling them.	The views of the workforce or its representatives should be sought and documented before monitoring is introduced, unless there is a good reason not to, and where the decision is not to, that decision should be recorded with a clear explanation. It should be done early in the planning and as part of the impact assessment.