EEOC Fact Sheet Highlights Compliance Risks Of Wearable Technologies In The Workplace

January 6, 2025

 

What's New

Wearable technologies in the workplace are the subject of a fact sheet released by the Equal Employment Opportunity Commission on December 19, 2024.

Examples of wearable devices include smart watches that track employees’ activities or monitor their condition, proximity sensors that warn wearers of nearby hazards, smart glasses and helmets that measure the brain’s electrical activity, and GPS devices that track location.

What It Means

Wearables in the Workplace: Using Wearable Technologies Under Federal Employment Discrimination Laws reminds employers that employment discrimination laws apply to the use of wearable devices.

The fact sheet cautions that collecting workers’ biometric data could be considered a medical examination under the Americans with Disabilities Act.

Furthermore, an employer could violate various statutory nondiscrimination requirements by using information from wearables to make employment decisions that adversely affect employees on the basis of a protected characteristic—such as race, color, religion, sex, national origin, age, disability, or genetic information. In addition, an employer may not use wearables to selectively monitor employees based on a protected characteristic or in retaliation for engaging in protected activity.

What You Should Do

Employers that use wearable technologies in their workplaces should consider the data that they are collecting, including their accuracy and validity across different protected bases; how they store the data; how they use the data in employment decisions; and whether that use has different impacts for employees with various protected statuses. CWC members who need help can contact CWC through MemberAssist at [email protected].





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