Joke Bodewits of Hogan Lovells writes:
The Dutch Supervisory Authority (Autoriteit Persoongsgevens or “AP”) has published a privacy booklet that primarily aims to support Works Council in its role with regard to privacy under the GDPR. Whilst the booklet provides some helpful clarifications on the AP’s interpretation of “employee monitoring systems,” it also contains statements that are not in line with the Dutch Works Council Act (WCA) and the General Data Protection Regulation (GDPR), resulting in new discussions on the Works Council’s role and responsibilities. This has created legal uncertainties and may lead to conflicts between employers and Works Council.
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