What should we include in our DPIA about staff?

Staff may also be data subjects because their voice, name, user ID and statements can form part of a recording.

The organisation should tell staff how recording and processing will operate and should define appropriate access and use controls.

Recorded conversations should not automatically be treated as staff performance monitoring.

If the organisation proposes to use recordings or transcripts for performance management, quality scoring or other secondary purposes, it should assess that processing separately.