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ARTICLE · 21 APRIL 2026

Luxembourg Employee Monitoring Guidance Note

Loyens & Loeff
Loyens & Loeff
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Loyens & Loeff

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Luxembourg's data protection authority has issued comprehensive guidance on employee monitoring practices, addressing the legal boundaries employers must navigate when implementing surveillance measures in the workplace. The guidance clarifies permissible monitoring methods, from telephone recording and CCTV to biometric systems, while emphasizing core data protection principles that govern employer-employee relationships.

LuxembourgPrivacy

Our Data Protection & Privacy counsel has contributed with an in‑depth guidance note to OneTrust DataGuidance, focusing on employee monitoring in Luxembourg. This comprehensive publication provides a detailed overview of the Luxembourg legal framework and the practical requirements for employee monitoring, helping organisations navigate compliance with national law and the General Data Protection Regulation (GDPR).

Key topics covered in the guidance note include:

  • Legal framework: overview of the GDPR and key Luxembourg laws relevant to employee monitoring, as well as guidance from the Luxembourg National Commission for Data Protection (CNPD).
  • Core principles: Key data protection requirements, including proportionality, transparency and data minimisation, and the general prohibition of permanent or covert surveillance.

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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