Sally AI: How We Guarantee Legally Compliant Works Council Communication

The introduction of new technologies in the workplace—especially those that process personal data—often raises legal concerns. In Germany, this is particularly true when it comes to ensuring compliance with the Works Constitution Act (BetrVG), the General Data Protection Regulation (GDPR), and the Federal Data Protection Act (BDSG).

Sally AI, our intelligent meeting transcription tool, has been developed specifically to meet these legal requirements. Below, we outline the legal framework and explain exactly how Sally supports works council compliance in every respect.

1. The Legal Framework: Co-Determination Rights Under Section 87 BetrVG

According to Section 87 (1) No. 6 of the BetrVG, the works council has co-determination rights when technical systems are introduced that may be used to monitor employee behavior or performance.

Because Sally transcribes meetings, thereby theoretically capturing participants’ speech or behavior, it falls under this category. That’s why we’ve built in safeguards to meet all compliance criteria:

• Employee Involvement: Before Sally is introduced, companies coordinate with the works council to protect employee rights and collaboratively develop a tailored works agreement.
• Defined Purpose: Sally is strictly limited to meeting transcription. Any use for surveillance or monitoring is explicitly excluded.
• Data Security by Design: All transcripts and audio recordings are protected using advanced encryption standards such as AES-256 and TLS, ensuring confidentiality and preventing unauthorized access.

2. Data Protection Compliance: GDPR and BDSG

GDPR and BDSG impose strict standards on how personal data is handled. Sally was built with full compliance in mind, reflecting these core principles:

• Purpose Limitation (Article 6(1) GDPR): Data is processed solely to document meetings. Sally is configured to prevent any unrelated or unauthorized data use.
• Data Minimization (Article 5(1)(c) GDPR): Sally captures only what’s essential—no video, no metadata tracking, no extras. Just audio-to-text transcription.
• Employee Rights (Articles 15–20 GDPR): Users can access, correct, or delete their data at any time. Sally includes simple tools for quick, transparent data handling.

3. Transparent Implementation and Participation

Our experience with large-scale deployments shows that early and open collaboration with works councils is key to success. For clients with over 10,000 employees, we have supported the entire process of co-developing a works agreement that covers:

• Full Documentation: Every aspect of Sally’s functionality and data handling is clearly documented for both companies and works councils.
• Custom Configuration: Sally can be adapted to each company’s requirements. Retention periods, data categories, and access controls can all be customized.
• Proactive Collaboration: We involve the works council from the very beginning to address any concerns and ensure smooth implementation.

4. Case Study: How We Work with Works Councils

From midsize businesses to major corporations, we’ve successfully partnered with works councils across industries. One standout example:

At the specific request of a client’s works council, we disabled video recording by default. While Sally is capable of recording video, this feature was turned off to avoid processing sensitive data that isn't needed for transcription.

This kind of flexible approach has led to dozens of successful implementations, backed by jointly developed works agreements that clearly define the scope and limits of Sally’s use.

5. Built for Compliance: Key Product Features

Our developers have ensured that Sally respects both data protection law and co-determination rights by default. Key features include:

• No Performance Monitoring: Sally does not track, analyze, or evaluate employee behavior or contributions.
• User-Controlled Activation: Transcription can be switched on or off by users at any time, putting control in their hands.
• Customizable Settings: Companies can define their own data handling policies, including storage periods and exclusion of specific data types.
• Consent-Based Participation: Sally only records meetings when explicitly activated. Recording without consent is not possible.
• Easy Opt-Out: If Sally joins a meeting by default but is not needed, simply type “opt out” in the chat. Sally will leave immediately, and all data up to that point will be permanently deleted.

6. Conclusion: Legally Sound and Future-Ready

Sally AI delivers maximum compliance and full transparency, so companies can focus on modernizing their workflows without legal uncertainty. With customizable features, data minimization, and proven collaboration with works councils, Sally sets the standard for responsible AI in the workplace.

We’ve successfully implemented Sally across companies of all sizes and are ready to help you do the same. Let’s work together - with your works council - to create a digital meeting culture that’s both efficient and legally secure.