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PDPS fining Evolution Georgia LLC for recording women change

ქართული დედანი

The Personal Data Protection Service recognized Evolution Georgia as a violator and fined the company

As widely reported, on July 11, 2024, the online media outlet “Mautskebeli” released a video (censored) [Preview] showing that 24-hour video monitoring was being conducted at Evolution Georgia, including in areas where employees, including women, were changing clothes. Evolution Georgia requires employees to change out of their personal clothing and into a uniform prescribed by the company. During this process, employees are in a semi-naked state. The security service, which is staffed entirely by men, had access to the video footage both during recording and afterward. This situation is particularly sensitive for female employees. The Personal Data Protection Service found that video monitoring was carried out in this manner during its investigation.

The Service determined that the cameras' field of vision included the entrances to the changing rooms in the A and E buildings, as well as the space in the female locker room on the minus-one floor of the A building, which is used for recreation and personal purposes.

According to the Service, spaces used by individuals for private activities fall under the regulation of Article 10, Paragraph 4 of the Law on Personal Data Protection. This article prohibits video surveillance in changing rooms, hygiene areas, or any location where individuals have a reasonable expectation of privacy. Monitoring in such areas, the Service concluded, violates generally accepted moral norms.

On October 15, 2024 (the decision was formally communicated to Labor on November 6), the Personal Data Protection Service recognized Evolution Georgia LLC as a violator and fined the company 2,000 GEL. The Service also issued the following orders:

• To cease video monitoring of the entrances to the changing rooms located in the A and E buildings.

• To stop video surveillance of the lounge area in the female locker room on the minus-one floor of Building A.

• To delete all video recordings from cameras located in the changing rooms of the A and E buildings, which show the entrances and rest areas of the changing cabins.

This decision, along with the actions taken against the head of Evolution Georgia's security service, confirms that during employee changing times, the company did not ensure the privacy and security of its workers. Employees were potentially exposed to surveillance by the security staff, creating an atmosphere of unwanted scrutiny. The company even used this issue to discredit the trade union and one of the active participants in the strike, manipulating the situation to foster division between strikers and non-strikers.

Labor and the strikers hope that, in light of these decisions, at least some of the non-strikers who had defended the company’s actions and criticized the union—will realize that they too have been victims of the company’s manipulation.