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Bossware: CDT and GFI Lead Broad Coalition Warning White House of Risks of Workplace Electronic Surveillance and Automated Management

(WASHINGTON)–The Center for Democracy & Technology (CDT) and Governing for Impact (GFI) have joined a coalition of 14 organizations to submit detailed comments to the White House Office of Science and Technology Policy (OSTP) in response to its Request for Information (RFI) on the important issue of electronic surveillance and automated management in the workplace. 

The comments present a comprehensive analysis of the risks associated with workplace surveillance and automated management tools and emphasize the need for responsible and transparent policies to protect workers’ health, safety, privacy, and dignity.

“As electronic surveillance systems continue to increase in both sophistication and prevalence, it is critical that policymakers take steps to ensure that their use in the workplace does not harm workers,” said CDT President & CEO Alexandra Givens. “CDT is grateful for the Biden Administration’s focus on this issue, which will only rise in importance in the coming years. These comments lay out the risks that surveillance and automated management systems can present to workers and share concrete steps that the Administration can take to protect workers’ safety and workers’ rights.”

Rachael Klarman, Executive Director of Governing for Impact, said, “Workplace surveillance can threaten workers’ rights.”

“The Biden administration has the authority to better regulate this technology, and we hope our comment helps spur immediate action to protect American workers,” she said.

The comments are organized around the different types of threats that surveillance and automated management systems can pose to workers, specifically:

  • How these tools threaten the health and safety of workers;
  • How these tools are used in ways that discriminate against vulnerable workers and exacerbate structural inequalities in the workplace and labor market;
  • How these tools can chill and infringe on workers’ rights to organize and to engage in protected labor activities; and
  • How companies use these tools to deprive workers of earned compensation.

The comments include specific recommendations for how federal agencies–including the Department of Labor, Equal Employment Opportunity Commission (EEOC), Federal Trade Commission (FTC), National Institute for Occupational Safety and Health (NIOSH), and Occupational Safety and Health Administration (OSHA)–can use regulation and public education to prevent and mitigate these risks. The signing organizations hope the OSTP’s request for information is the first step toward concerted interagency action to confront this rising threat to US workers. Some of these recommendations draw from memoranda that CDT, GFI, and many of the other signatories to these comments sent to OSHA and NIOSH earlier this year.

The full comments are available here. (Updated June 30, 2023)


The Center for Democracy & Technology (CDT) is the leading nonpartisan, nonprofit organization fighting to advance civil rights and civil liberties in the digital age. We shape technology policy, governance, and design with a focus on equity and democratic values. Established in 1994, CDT has been a trusted advocate for digital rights since the earliest days of the internet.