Employee monitoring law · Poland
The Labour Code lists the permitted purposes, and productivity is not one of them.
Check your purpose against the Labour Code list first. Measuring productivity is not on it.
- Region
- Europe
- Instruments
- 2 governing
- Employer duties
- 4 listed
- Last reviewed
- August 22, 2026
Poland · what the law requires
Notice and proportionality
Article 22² of the Labour Code sets out an exhaustive list of purposes for which monitoring may be introduced: employee safety, protection of property, control of production, and protection of information whose disclosure could harm the employer. Purposes and scope must be set out in a collective agreement, work regulations or a notice, employees informed before it starts, and certain areas, including union premises, are off limits.
- A listed purpose, onlySafety, property, production control, or protection of information. Measuring productivity for its own sake is not on the list.
- Written into the work regulationsPurposes, scope and method go into a collective agreement, the work regulations or a formal notice, not into an email.
- Notice before it startsEmployees must be informed in advance of introduction, and new joiners before they are given access.
- Protected areasMonitoring may not extend to premises made available to trade unions, nor to areas where it would breach dignity.
- Proof Ledger
- Outcomes
- Certificates
- Audit log
- Data access
- Disputes
- Data egress
- Export
- What We See
- Controls
- AKAria K. viewed screenshotsLena M. · 3 capturesScreen capturemacOS · London09:42a91f…4c023d7b…91ee
- JMJon M. exported time reportDesign team · CSVmacOS · Berlin09:313d7b…91ee77c5…0ba4
- SDSara D. opened capture reviewRavi P. · one flagged frameWindows · Manchester09:1877c5…0ba4e208…5f13
- wm_live_7f2… read /v1/deliverablesScoped key · read onlyPublic API · allowlisted IP08:57e208…5f13b64a…2d90
- LMLena M. viewed her own recordWhat We SeemacOS · London08:44b64a…2d901cf9…8e77
- AKAria K. changed capture policyBlur set to alwaysmacOS · London08:261cf9…8e7705d2…ae31
The instruments, and which control answers each duty
- GDPR: Regulation (EU) 2016/679. Sets the floor everywhere in the EEA: a lawful basis, purpose limitation, data minimisation, transparency and a DPIA where monitoring is high risk. National law below adds to this, never subtracts.
- Labour Code: Kodeks pracy art. 22² and 22²ª. Exhaustive purposes for monitoring, the duty to record scope in work regulations or a collective agreement, and the two-week notice before introduction.
No product does this part
What you must still do yourself
Compliance is a property of your deployment. These are the steps in Poland that no vendor can complete on your behalf, and skipping them is what turns a rollout into a finding.
- 1Amend the work regulations or collective agreement to state purposes, scope and method.
- 2Give notice before introduction, and to each new joiner before access.
- 3Consult trade unions where they exist, and keep monitoring out of their premises.
- If you get it wrongUODO fines under the GDPR, plus labour-inspectorate sanctions for breach of the Labour Code provisions.
Verify the claim
Every control above, on the page that describes it
- Anomaly and integrity feed with the underlying activity attachedSupport an information-protection purpose with evidence
- Capture policies stated per team with the policy version in force recorded per dayKeep the configuration matching what the work regulations say
- Notice and consent record carrying version and dateDemonstrate advance notice per person
Sources and review date
Last reviewed August 22, 2026This is a summary of how employee-monitoring rules generally work in this jurisdiction, written to help you scope a rollout and brief your own advisers. It is not legal advice, it is not a substitute for it, and law changes. Verify against the primary sources listed and take local counsel before you deploy.
Nearby jurisdictions
Monitoring law elsewhere in Europe
- United KingdomThe ICO's 2023 monitoring guidance is the operative document, and it expects a DPIA.
- IrelandThe DPC accepts a legitimate business interest, and then tests proportionality hard.
- SwedenCo-determination negotiation before any significant change, including this one.
- NorwayControl measures need discussion with employee representatives and periodic review.
- DenmarkSix weeks' notice under the collective agreement framework, and a strict purpose test.
- GermanyThe works council holds a veto, and a productivity dashboard is enough to trigger it.
Point it at one team for a week.
Create the account, put the agent on a handful of desks, and leave it alone. On Friday you read the week instead of reconstructing it: hours against their projects, focus and idle per person, and the timesheets already filled in.
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