Stjörnuna ehf, the operator of Subway in Iceland – €1,020 Fine (Iceland, 2024)

The data subject is an employee at Subway in Iceland. The controller is Stjörnuna ehf, the operator of Subway in Iceland. The data subject filed a complaint to the Icelandic DPA (Persónu­vernd) on 4 May 2021. The data subject claimed that the store manager was at home monitoring the data subject in real time and called the workplace to give comments on the data subject’s work style based on the footage. This was done without the data subject’s knowledge. The controller argued in a letter to the DPA that it had installed the surveillance cameras for the sake of security and property protection. The surveillance camera system was used in a reasonable manner and it was been used for the control of workers or for monitoring work results. The controller claimed that the store manager went beyond the stated purpose of the monitoring and used the footage to monitor the work performance of the employees without the consent or knowledge of the company representatives. Immediate action was taken to prevent this from happening again. However, in a following letter, the controller denied that the store manager regularly monitored staff in real time through the restaurant's surveillance camera system and commented on their work style and behaviour. The controller argued that the store manager was looking at the surveillance camera system on the day in question out of fear that bread was running out. However, the store manager noticed that there was a big queue which did not change after 5 minutes, and therefore called the data subject who was in the rest area to request that the data subject serves the customers. Lastly, the controller argued that since there was no systematic collection of information, they had no obligation beyond the installation of signs about the surveillance cameras in the workplace to inform employees more about the monitoring. Firstly, the DPA found the arguments of the controller conflicting as the purpose for processing was either (1) in the inter