Workday Registration – HR

Workday Registration

The Workday Record shall not remain in a place of public access or be visible to other workers.

According to a publication made by the Spanish Data Protection Agency last May, an employer who uses paper documents to control working hours in order to comply with Article 34.9 of the Spanish Data Protection Law (Article 34.9 of Royal Legislative Decree 2/2015 Law of the Statute of Workers.The record may not be kept in a publicly accessible place or be visible to other employees, therefore it is recommended that an individual workday record be prepared for each employee and that it is always in the custody of authorized personnel in charge of managing the workforce, preventing other workers from checking data of other colleagues.

The same should be done if the registration is carried out by any other means (computer applications, intranet, other platforms, etc.). The objective is to comply with the employer’s obligation of confidentiality and secrecy.

On the other hand, the Workday Register shall be included as an Activity, within the Treatment Activities Register(RAT), prepared by each employer(Data Controller).