Sally AI: This is how we ensure legal works council compliance.

The introduction of new technologies in companies, in particular those involving potentially personal data, repeatedly raises questions about compliance with legal requirements. In Germany in particular, when implementing such technologies, the rights of the works council are subject to Section 87 Works Constitution Act (BetrVG) as well as the provisions of General Data Protection Regulation (GDPR) and the Federal Data Protection Act (BDSG) to note. Sally, our tool for automatic transcription of meetings, was developed explicitly in such a way that it fully meets these requirements. In the following, we explain the legal framework and show how we ensure that Sally complies with the works council in every respect.

1. Legal framework: Works Council's right of co-determination (Section 87 BetrVG)

In accordance Section 87 (1) No. 6 BetrVG The works council has a right of participation in the introduction and use of technical facilities which are suitable for monitoring the conduct or performance of employees. Sally falls into this area because, by transcribing meetings, statements or behavior of participants can theoretically be documented.

In order to meet the requirements of Section 87 BetrVG, we have taken the following measures:

• Employee participation: Prior to the introduction of Sally, there is a coordination with the works council in order to protect the rights of employees and to work out a works agreement together.
• Clear purpose: The use of Sally is strictly limited to transcribing meetings. Other uses that are potentially supervising are excluded.
• Data security through encryption: All transcripts and audio recordings are protected by cutting-edge encryption methods such as AES-256 and TLS to prevent unauthorized access and ensure data confidentiality.

2. Data protection requirements (GDPR, BDSG)

The General Data Protection Regulation (GDPR) and the Federal Data Protection Act (BDSG) set high standards for handling personal data. In particular, the following principles must be respected:

• Purpose (Section 6 (1) GDPR): Data may only be processed for clearly defined and lawful purposes. Sally is configured so that transcripts are only created to document meetings and are not used for other purposes.
• Data minimization (§ 5 para. 1 lit. c DSGVO): Sally only collects the minimum necessary data. No video recordings, no metadata analyses — just pure audio transcription.
• Rights of data subjects (§§ 15-20 GDPR): Employees have the right to access, correct or delete their data at any time. Sally supports this with intuitive functions that enable fast and transparent data processing.

3. Transparency and participation in implementation

Our experience with implementing Sally for major customers shows that early and transparent involvement of the works council is crucial. For customers with more than 10,000 employees We worked closely with works councils to draw up a works agreement that regulates the use of Sally. In particular, the following points were taken into account:

• Transparent documentation: The use of Sally is fully documented. Companies and works councils receive all necessary documents on technical functioning and data protection standards.
• Configuration flexibility: On request, Sally can be customized to meet the specific requirements of a company and its works council. For example, retention periods for transcripts can be defined or certain categories of data can be excluded from processing.
• Early involvement: We ensure that the works council is involved in the implementation process from the outset in order to resolve concerns or ambiguities at an early stage.

4th experience report: Cooperation with works councils

In our previous work with customers of various sizes — from medium-sized companies to large companies with more than 10,000 employees — we have worked closely with works councils. Particularly noteworthy is our flexibility to meet the individual requirements of each company.

One example of this is the Deactivation of the video recording function at the express request of the works council. Although Sally also allows video recording by default, this feature can easily be turned off to ensure that no sensitive data is collected that is not required to transcribe a meeting. These adjustments have already been successfully implemented in several projects.

In addition, we have supported numerous works agreements that explicitly regulate how and for what purposes Sally is used. Our team ensures that all legal requirements are recorded and taken into account in the agreements.

5. Specific adjustments for works council compliance

Our developers have designed Sally in such a way that it does not offer any control mechanisms that could conflict with the works council's participation rights or data protection requirements. Key adjustments include:

• No performance control: Sally neither analyses nor evaluates individual people's participation or contributions to the meeting.
• User-friendly control: Users can manually turn on or off the transcription function at any time, which ensures maximum control over the processing of data.
• Individual adaptability: Companies can implement specific requirements — such as setting retention periods or excluding certain categories of data — directly with us.
• Participation and recording by Sally: In every meeting, there is an individual option to let Sally participate and record that meeting. Participation in meetings and recording them without Sally's express consent is excluded. Among other things, this guarantees prior consent to the recording of personal data.
• Safely remove the bot from the meeting: If Sally automatically attends a meeting due to default settings but is not desired, the immediate removal of Sally is guaranteed by entering “opt out” in the meeting. All data recorded up to this point will be completely and irrevocably deleted.

6. Conclusion: Maximum compliance, maximum protection

Sally meets all legal requirements for works council and data protection compliance. With individually customizable functions, strict data minimization and a clear focus on transparency, we offer companies the assurance that the use of Sally is not only efficient, but also legally correct.

Our expertise in working with companies of all sizes — from medium-sized customers to large corporations with more than 10,000 employees — guarantees that Sally can be seamlessly integrated into existing structures while taking full account of employee participation rights. We would be happy to sit down with you and your works council to find the optimal solution for your requirements.

We are always available for further information or to answer specific questions. Together, we are shaping the path to a digital and legally compliant meeting culture.