Flexitime at DG INFSO - Commission

Within the general framework of Time management regulated by the "SYSPER 2 Time management system", DG INFSO added to the application of Flexitime an additional and important component in the element of a RFID chip integrated in the personal badge necessary to clock in and out. The inclusion of such a technology into a flexitime system thus reinforces the specific risks already present in the system. Therefore, the EDPS considered the case as such subject to prior checking.

 

In his analysis, the EDPS concluded that the system does process personal data because the data relate to natural persons who are identifiable, for instance by the use of names, personal numbers. Furthermore, the EDPS analysed closely the necessity test applied to the system and concluded that there was not a specific need to develop a badging system using RFID to implement a flexitime system, as the same purpose (management of working hours) could be reached by other, less intrusive, means.  However, the EDPS also accepted that "need" does not mean that it is unavoidable but that it can be considered reasonably necessary in the specific context for fulfilling the purpose aimed at. Therefore, a margin of appreciation is left at the discretion of the administration in deciding to implement this system using RFID. If the safeguards and proportionality are present, it can be considered that such a system fulfils the conditions of need.