In Depth back to UNI In Depth home page 06/26/2006 UNI's letter to EU Commissioner Viviane Reding on RFID technology in Europe Dear Commissioner Reding, Union Network International and UNI-Europa warmly welcome the debate which you have initiated on the development of RFID technology in Europe. We believe that this consultation and debate is timely. We ourselves have recently undertaken an extensive study of the use and potential use of RFID (and, more broadly, on the implications of other technologies, such as GPS tracking) in the workplace. This study identifies some ways in which RFID can be used positively in the workplace context but it also identifies a number of areas of concern, some of which we feel are significant. We look forward to the opportunity to contribute our perspective to the debate. More generally, we would welcome the issues raised by RFID in the workplace being addressed in Europe through a process of active social dialogue. We were pleased to see the significance you gave to issues of privacy and surveillance in your speech at the CeBIT summit in Hannover last month and we strongly welcome your pledge that RFID will not compromise the liberty of citizens and their fundamental rights. In the particular respect of RFID in the workplace, we can summarise our own areas of concern as follows: Firstly, the introduction of RFID tags in certain industries (for example in warehouse management) is on some occasions being accompanied by major restructuring of the working environment, to the extent that the work is increasingly becoming dehumanised. There is a growing trend to use RFID for employee tracking, typically using RFID tags attached to name badges or security passes. Data captured from RFID tags are increasingly being integrated with personnel files (for example, being linked to employee time sheets, pay records and health records). There is evidence that many employees are not aware that this information is being collected. We seek measures to control these examples of data collection ‘creep’. There are particular risks that employees may continue to be automatically monitored via RFID (through name tags etc) when they are off-duty, such as in evenings, weekends and holidays. We would seek measures to make this illegal. We are also concerned at employee tracking via RFID during work breaks, lunch breaks, toilet breaks etc. We therefore welcome discussion about the ways in which RFID tags could be temporarily disabled. We note that RFID tags have in a small number of cases been sewn into employee uniforms. We believe this increases the risk of unacceptable employee tracking and surveillance. We believe there should be measures to ensure that any use of RFID tags in uniforms or work clothes is limited strictly to laundry management functions. We are completely opposed to the concept that workers could be implanted with RFID tags (as proposed for example by the makers of the VeriChip). We would welcome a higher level of debate on the possible health and safety implications of RFID use in the workplace. We note that studies have suggested a correlation between excessive employee monitoring and workplace stress. Employee tracking and monitoring using RFID is one of a number of complementary technologies which, taken together, could lead to an unacceptably high level of worker surveillance. We also have concerns about the development of the related technology of wearable computers (for example, wrist and finger scanners). We are concerned to ensure that workers’ personal data, including data acquired from RFID, are adequately protected in the workplace in line with data protection principles. We share with the European Art29 Data Protection Working Party (report WP105 10107/05) a concern about “the possibility for some applications of RFID technology to violate human dignity”. Our particular starting point is the protection of the fundamental human dignity of workers within the workplace environment. We will shortly be launching the UNI Code of Good Practice for RFID in the workplace. We hope that this will help both the European debate about RFID you have initiated and the process of social dialogue in Europe in relation to RFID technology. We will ensure that you are sent a copy of the Code. We would welcome the opportunity for trade union representation at any future events similar to the RFID consultation launch at Hannover. Yours sincerely ______________________ Union Network International http://www.union-network.org - contact@union-network.org