UNI-Europa's submission to the public consultation on RFID
Recent years have seen a considerable increase in the extent of electronic monitoring and surveillance in the workplace, including the introduction of new and higly sophisticated digital technology tools, RFID (Radio Frequency Identification) is one of them.
By far the most common use of RFID chips in the workplace are in name tags and identity badges worn to control entry to buildings and rooms. Although taken for granted as a normal security feature in many workplaces these days, RFID-equipped identity badges in reality provide data for far more than entry systems. Typically data collected are linked to other company databases, including human resource managment and payroll records.
The Commission is preparing a Recommendation that will address the issues raised by the use of RFID in terms of privacy, data protection and information security. As part of this preparation the Commission has decided to put up for public consultation all the articles that are currently being considered in its draft Recommendation. The public consultation closed today, 25 April 2008. The Commission services will now analyse the received contributions and put forward a draft Recommendation for adoption before the summer of 2008.
The recommendations concerning privacy measures, self regulation (codes of conduct), information on RFID use, and information security risk management are applicable to all RFID applications and to all economic and social sectors. The Commission believes that the retail sector requires additional guidance because of the specific characteristics derived from the potentially large dissemination of consumer products carrying RFID tags. However, the Commission does not believe that RFID in the workplace requires the same attention.
UNI-Europa strongly believes that the Recommendation on RFID should include the need to elaborate practical guidance with the social partners and a clarification of the obligations of the parties operating RFID applications at the workplace. This is the message UNI-Europa is sending the Commission in the submission to the public consultation.