PI's response to the UK Goverment's consultation on workplace monitoring technologies

Our submission covers the following topics, following the government's consultation on workplace monitoring technologies:

• Gaps in the principles around data minimisation and purpose limitation, including the risk of "scope creep" (such as a driver-facing camera introduced for road safety being repurposed for disciplinary action), and the need for a clear prohibition on selling or sharing worker data beyond its original purpose, including following a company's bankruptcy or closure.
• The limits of anonymisation and aggregation as safeguards, given the risks of re-identification and the fact that even perfectly anonymous data can be used to leverage employer power and information asymmetries against workers.
• The need for greater stringency on transparency and explainability in automated decision-making (ADM), including clear explanations of how algorithms work, whether decisions are advisory or decisive, and personalised explanations for individual decisions, without which the appeal route under the human oversight principle is ineffective.
• Evidence from PI's research on AI recruitment platforms, work-from-home monitoring software, the gig economy and the creator economy, covering opaque algorithms, information asymmetries between employers and workers, unannounced monitoring and the observer effect, and the lack of any effective route to challenge decisions once made.
• Anti-retaliation protections, and what meaningful worker engagement looks like in practice, including consultation before WMT is proposed, access to sandboxes, API access or source code for workers, unions and technical experts, worker involvement in impact assessments, and a requirement to consult and negotiate with trade union or employee representatives before WMT is introduced.