Assess the permitted reason and risk
Before monitoring employees, document the purpose, permitted processing reason and necessity; give a clear employee notice and assess privacy impact where appropriate. Employee consent alone should not be treated as proof that a deployment is lawful. Review any applicable permission requirements and less intrusive alternatives.
Minimize and separate access
Where feasible, prefer protected templates over raw biometric images and avoid GPS collection beyond the defined attendance need. Encrypt supported device-to-server and API connections. Separate payroll, reporting and device-administration roles; record changes and exports. Confirm cloud locations and processor contracts.
Plan offboarding and deletion
Set approved retention for templates, photos and attendance history separately. Revoke access and remove device records at offboarding when permitted. Verify deletion across devices, servers, integrations and backup expiry; retain only where a documented obligation requires it.
Planning recommendations are distinct from legal obligations. Confirm the rules and current specifications for your facility, sector and contract. This guide is not a certification or legal opinion.