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Iceland: Persónuvernd releases new rules on electronic monitoring

The Icelandic data protection authority (Persónuvernd) announced, on January 27, 2023, the issuance, on January 10, 2023, of Rules No. 50/2023 on electronic monitoring, which entered into force immediately, thereby repealing the existing Rules No. 837/2006 on electronic monitoring and processing of personal data generated during electronic monitoring. At the same time, the Persónuvernd also published guidelines covering the monitoring of emails, filing systems, and internet use, as well as new sample information signs and training templates.

Rules No. 50/2023

Rules No. 50/2023 apply to electronic monitoring in public or private areas, such as workplaces, schools, and other areas accessed by a limited group of people, regardless of the type of equipment used. In this regard, the Persónuvernd highlighted that, compared to Rules No. 837/2006, Rules No. 50/2023 do not include special provisions on emails and internet use. More specifically, Rules No. 50/2023 define some key terms, such as 'electronic monitoring,' 'work performance monitoring,' and 'driver logs,' and regulate, among other things:

  • the processing of personal data that takes place in connection with electronic monitoring;
  • data subject rights;
  • information provision when carrying out electronic monitoring;
  • the sharing and storing of personal data generated due to electronic monitoring; and
  • the monitoring of work performance.

Notably, Rules No. 50/2023 ban secret monitoring.


Separately, the guidelines mainly address the monitoring of emails, filing systems, and employees' internet use at the workplace, including any issues arising before the beginning of the employment relationship, and an employer's authority to inspect mailboxes after the termination of an employment relationship. The guidelines may also be used as a guide in other similar situations, such as at school.

You can read the announcement here, Rules No. 50/2023 here, and the guidelines here, and download the sample information signs here and here, and the training template here, all only available in Icelandic.