That's how we have done it, AUP and IGS policy.
I would see it more as a contract processing condition though rather than a legitimate interest, we ask new staff to sign the acceptable use and information governance and security policy, it is also in the staff handbooks so for staff who are in a contract of employment this would be my determination of the processing condition.
I have also found out that just because the intended use of the information logged is not necessarily for monitoring or performance management, it can be and should be communicated to staff, and access to the data locked down to those who have a need to see the information. An example of this is a health and safety device that logs the location of staff working remotely, it logs the location, time and length of time in a location. The purpose is for health and safety but it then gets dragged out for use in performance meetings or disciplinary hearings.
Regards
Darren
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Palmer-Dunk, Dan
Sent: 03 June 2019 13:49
To: [log in to unmask]
Subject: Re: [data-protection] Privacy notice for staff and digital footprint
The existence and use of this kind of information (audit logs, etc.) can also form part of your AUP and security policy, to which you might want to refer in the staff privacy notice and contract.
Dan
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Emile Douilhet
Sent: 03 June 2019 13:39
To: [log in to unmask]
Subject: Re: [data-protection] Privacy notice for staff and digital footprint
Hello Danny,
I have it as a more general statement based on Legitimate Interests. There are many things internal IT services can do in relations to gathering reports based on a digital footprint (I would not put them all in a privacy notice as you will end up with a whole book), but since these should only happen on a legitimate purpose LI is applicable.
Emile
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