Writing the Notice

The transparency obligation is met by a document nobody reads and defeated by it. The version that works answers what people ask.

The six questions

Can it see where I am when I'm not clocking in?

What happens if it won't let me clock in?

Will I be paid if the app fails?

Do I have to use my own phone?

Who can see my location?

How long is it kept?

Answer those six, in that order, in plain sentences. The formal notice can exist alongside; this is the one that gets read.

Writing it

Second person. "The app checks your position when you tap to clock in."

Specific. "Only at that moment" rather than "as necessary for the purpose".

With the negatives stated: it cannot see your location when the app is closed, we do not track you during your shift, we do not use this to check up on anyone.

And the pay sentence, plainly: if the app fails, you clock in anyway, you start work, and you are paid.

One page, dated.

Show them how to check

The phone's own permission screen shows what the app is allowed to do.

Walk through it once, at the briefing.

This is the single most effective thing you can do, because it converts a claim into something the person verified themselves.

And it only works if the claim is true, which is the discipline it imposes.

Delivering it

In person, with questions. A document emailed to a site is not a notice in any useful sense.

Demonstrate a refusal and what happens next, which is the thing people most want to see.

To new starters as part of joining.

Again when anything changes, including after an app update that alters permissions.

What undermines it

Claims that are not true, which are checkable on any phone and will be checked.

Vague scope: "may collect location data" tells people you would rather they did not know.

Silence after a change, which teaches everyone that the notice describes intentions rather than the system.

The test

Ask three people what the app collects.

Wrong in the direction of assuming more means the notice failed and you are paying for it in workarounds.

Wrong in the direction of assuming less is worse, and it is the situation that produces a grievance.

Show the permission screen

The single most effective thing in the briefing.

Walk through the phone's own settings, where the app's location permission is visible.

It converts a claim into something the person checked themselves.

It works only if the claim is true, which is the discipline it imposes on the design.

Two minutes, and it does more than a page of policy.

Check the difficult case

Use view a practical reference to frame one representative test. The useful evidence is the record created when an employee corrects an entry and an administrator exports it.