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2. Employee monitoring

In respect of employee monitoring, the PCPD published the “Privacy Guidelines: Monitoring and Personal Data Privacy at Work” in December 2004 which were revised in April 2016. Although these guidelines are not legally binding, they are made with reference to the Six Data Protection Principles of the Ordinance and therefore have substantial reference value. The guidelines list out some recommended steps that should be taken by employers when they monitor employees using the following means:


  • Telephone Monitoring (telephone calls and voice mail made or received by employees)
  • E-mail Monitoring (employees' incoming and outgoing e-mail messages)
  • Internet Monitoring (employees' web browsing activities)
  • Video Monitoring (using video cameras or CCTV to monitor or record employees' work activities and behaviours)