Mass Collection of Workers’ Data in Warehouse Facilities: Reflections on Privacy and Workforce Well-being

Abstract

Warehouses with complex monitoring and algorithmic management policies are rapidly expanding across the EU. This paper explores the functionalities of a Warehouse Management System (WMS) and its role in managing warehouse workers. In particular, WMS implementation raises concerns regarding worker privacy and data protection due to the increased surveillance of warehouse operations, while at the same time also having the potential to significantly enhance worker well-being. By examining the WMS' features in relation to the GDPR (EU Reg. 2016/679) and the AI Regulation (EU Reg. 2024/1689), this paper establishes a framework in which worker well-being is fostered in accordance with data protection and technology law. Following an introduction to these regulations, we analyse three case studies of personal data acquisition and management policies from warehouse management literature. Building on these examples, this paper offers practical guidelines for researchers and practitioners to ensure their warehouse operations comply with current regulations on worker monitoring. We show that data collection practices and their implications should be more carefully considered, both by practitioners and researchers.