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Question:

Can an employer use covert surveillance to gather evidence to support a disciplinary action?               

 

 

Answer:

This is a complicated issue. However in at least one case; McGowan v Scottish Water [2005] in the EAT, Scottish Water used private investigators to spy on Mr McGowan at home. They believed that he was falsifying his timesheets, so they videoed his home to monitor his movements.

 

As a result of this surveillance Scottish Water dismissed him and in his subsequent unfair dismissal claim Mr  McGowan claimed that this covert activity breached Article 8 (right to respect for private life) of the Human Rights Act.

 

One might think that covert surveillance of an employee at his home was particularly intrusive, however Mr McGowan’s arguments were rejected. Although there was a strong presumption that Mr McGowan’s right to private life was being breached, the key issue is how ‘proportionate’ that intrusion was. In this instance the surveillance was crucial to establishing whether a potentially serious fraud was being committed. It was proportionate in the circumstances.

 

Though not giving the red light to peak over the garden fence every time an employee throws a sickie, surveillance may well be proportionate when investigating serious misconduct.  Putting CCTV cameras in the toilets of the workplace is unlikely to be proportionate.

 

See also our page on disciplinary proceedings

 

Last reviewed: July 2010

 

James Carmody

Employment Solicitor

 

Reculver Solicitors

12-16 Clerkenwell Road

London EC1M 5PQ

 

www.reculversolicitors.co.uk

info@reculversolicitors.co.uk

Tel 0207 324 6271

 

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