Privacy notice for employers (template)
1. Download
The template is provided as a Word document (editable) and a PDF (print-ready). Both are identical; the Word version exists so you can adapt the wording to your jurisdiction, your employment contract, or the specific request you are responding to.
This template is provided under the same terms as the rest of the OvertimeLog documentation. Re-use is permitted; attribution is appreciated but not required.
2. When to send it
You do not have to send this notice to use OvertimeLog. But there are three situations where doing so is a good idea:
- Proactive transparency. You prefer to be open about the fact that you are keeping a record, rather than surprise the employer with it later. Many lawyers recommend this because it neutralises later accusations of covert surveillance.
- A formal overtime / right-to-disconnect claim is approaching. Putting the employer on notice that the record exists, and what it covers, is a standard step in the run-up to any working-time complaint.
- The employer has asked. If someone on the employer side has heard about the tool and wants to know what it is, the template answers the usual questions in one page.
Conversely, if you are in the middle of a live dispute and intend to produce the record as evidence, talk to a lawyer first. Nothing on this page is legal advice.
3. What's inside
Here is the text you will see after opening the Word or PDF file:
Privacy Notice — Personal Working-Time Record
1. Purpose of this notice
This letter informs you that I, [EMPLOYEE NAME], am keeping a personal record of the times I am contacted for work outside of my agreed working hours. I am providing this notice in the interest of transparency and to describe what the record contains, how it is stored, and why I am keeping it.
2. Why I am keeping this record
Under the European Court of Justice judgment in CCOO v Deutsche Bank (Case C-55/18, 14 May 2019), employers are required to establish an "objective, reliable and accessible" system for recording the daily working time of each worker. Where such a system is not yet in place on the employer side, I am maintaining an employee-side record so that my actual working time can be demonstrated if required.
3. What the record contains
The record is limited to messages I receive or send in workplace chat (for example Slack direct messages) during periods that fall outside my agreed working hours. For each message, the record captures timestamp, channel name, sender/receiver username, the message text, a permalink back to the message, and a SHA-256 hash of the captured content. It does not contain biometric data, location data, or any information outside of work-related chat messages.
4. Where the data is stored
The record is kept only on my personal device, inside a local SQLite database file. It is not synchronized to any cloud service and is not shared with any third party. The software used (OvertimeLog) operates entirely on-device.
5. Legal basis for this processing
I am processing this information under Article 6(1)(f) of the General Data Protection Regulation (legitimate interests): specifically, the interest in being able to demonstrate my own actual working time and, where applicable, to support claims for overtime compensation.
6. Retention
The record will be retained only for as long as necessary to establish or defend claims relating to my working time and overtime compensation, typically in line with the limitation periods that apply to such claims in our jurisdiction.
7. Rights of other participants
Because the record includes messages sent by colleagues who are also parties to the conversation, I recognise those colleagues have data-subject rights under the GDPR and will respond in accordance with the applicable law and in good faith to any reasonable request.
8. Availability of the record
I will make the record available, in whole or in part, in response to any reasonable request from the employer or a regulator in the context of a working-time, overtime, or compliance dispute.
9. Contact
If you have any questions about this notice, please contact me at [EMPLOYEE EMAIL].
Sincerely,
[EMPLOYEE NAME]
[JOB TITLE]
4. Notes on adapting the template
- Jurisdiction. The template cites GDPR Article 6(1)(f) and the CCOO ruling because both apply across the EU. If you are outside the EU/EEA, replace the citation with the equivalent in your jurisdiction (UK GDPR, California CCPA, etc.) or drop it entirely; the rest of the letter reads fine without a specific legal citation.
- Tone. The default wording is formal but neutral. If your relationship with HR is friendly, you can shorten sections 6–8 considerably. If it is adversarial, leaving them in full is the safer choice.
- Do not over-promise. Do not state retention periods or specific limitation periods unless you have verified them for your jurisdiction. The default language ("in line with the limitation periods that apply") is deliberately generic.
- If you are in a works council or union context, share the draft with a representative before sending. They often have a better read on how the employer will react.
5. Related reading
- OvertimeLog Privacy Policy — what the software itself does with data.
- Disclaimer — what SHA-256 hashes prove and what they don't.
- FAQ — Legality & compliance — common questions around GDPR, CCOO, and workplace monitoring.
Template provided as-is by OvertimeLog. It is not legal advice, and its suitability for any particular jurisdiction or employment contract should be reviewed by a qualified lawyer before use.