notebooksbilliger.de AG

What happened

The Lower Saxony DPA fined notebooksbilliger.de €10.4 million for conducting video surveillance of employees without a legal basis for at least two years. The online electronics retailer had installed video cameras in workspaces, sales areas, and warehouses that continuously recorded employees. The company claimed the surveillance was to prevent theft, but the DPA found this was disproportionate because less intrusive measures were available, such as random bag checks or targeted surveillance of specific areas during specific timeframes. The blanket, permanent surveillance of all employees violated the data minimization principle and lacked a proper legal basis.

Articles violated

Lessons learned

Employee video surveillance must be proportionate and limited to specific, justified purposes. Blanket, continuous monitoring of all employees is almost never proportionate under GDPR. Before implementing surveillance, companies should consider less intrusive alternatives. Theft prevention can often be achieved through targeted measures rather than continuous recording. Document the necessity assessment and consider employee rights before installing cameras in workplaces.