INTRA/MD/MD017Monitoring on worker-owned devices
The operation of the program’s instruments on equipment owned by the worker.
| Control | Jurisdiction | Source | What it establishes | Prerequisite or recommendation |
|---|---|---|---|---|
| MD017/HUMandatory | Hungary | 2012. évi I. törvény a munka törvénykönyvéről, 9. §, 10. §, 11. §, and 11/A. §Országgyűlés · read 5 Oct 2026 | That an employee’s personality right may be restricted only where strictly necessary for a reason directly connected with the purpose of the employment and proportionate, with prior written information on the manner, conditions, expected duration, and the circumstances supporting necessity and proportionality; that the employee may be checked in the conduct connected with the employment, by technical means too, after prior written information; that a device provided for work is used only for the employment unless agreed otherwise and the employer may inspect the employment-related data stored on it; that biometric data serve identification only against grave unauthorized access; and that criminal record data may be processed to check a restriction or exclusion the employer has set out in writing beforehand. | Where by agreement the employee uses their own device for the employment, the employer’s right to inspect the employment-related data stored on it applies. |
| MD017/ESMandatory | Spain | Resolución del procedimiento sancionador PS/00454/2024Agencia Española de Protección de Datos · read 16 Aug 2026 | What an employer may require of a device it does not own, on facts of continuous recording, at a fine of 200,000 euros. | Requiring a worker’s own telephone to carry the instruments has drawn infringements of articles 13, 5(1)(c), and 6(1), a fine of 200,000 euros, and an order to bring the processing into line within two months. |