For the works council
Mindsetor only runs with your consent.
That is not a formality we hope to sidestep. Below is our position, what is processed, and what the employer never sees.
The right of consent applies. We say so ourselves.
Article 27 of the WOR touches this decision on three points:
- Section 1(d): an arrangement concerning working conditions and sickness absence.
- Section 1(k): an arrangement concerning the processing and protection of employees' personal data.
- Section 1(l): a facility aimed at, or suitable for, observing or monitoring presence, behaviour or performance. Being suitable is already enough. Intent does not matter.
If the employer decides without consent, the works council can invoke the nullity of that decision (Article 27(5)). A rollout without the works council is no rollout at all. So we schedule the works council route before the start, not after.
Three data flows, one reporting threshold.
- The screening. Validated questionnaires (BAT, WHO-5, PSS-4) plus workload and context questions. The employee sees their own result immediately. That result goes to no one else.
- The app. A 30-second daily check-in during team challenges. Optionally linked to a personal smartwatch. Never mandatory.
- The report to the employer. Aggregated only: the Organisation Workload Report per department.
Groups of 15 or more. Never an individual.
Nothing at person level. Not in any report.
- Individual screening answers
- Individual readings from app or smartwatch
- Who books or has booked a care session
- Groups smaller than 15, in any breakdown whatsoever
There is no screen on which the employer can view an individual. That makes the report technically unusable as an assessment tool: there is nothing to retrieve per person.
“At first I was careful about what I filled in, I didn’t know who saw my data. Later I simply entered what I really felt.”
Pilot programme participant
Then nothing happens.
Participation is voluntary. Not taking part costs nothing, is not recorded anywhere at person level and is not visible to managers.
The works council co-owns the report.
You receive the same Organisation Workload Report as the board, at the same moment. The report is a shared improvement tool, not evidence against anyone.
Judge us by the documents, not by this page.
- Data processing agreement (DPA)
- Data Protection Impact Assessment (DPIA)
- Privacy statement
- Sample of the Organisation Workload Report
- Model consent request: on request via support@mindsetor.com
We will explain this to your full works council.
A 30-minute session, online or on site. You set the agenda. The more critical the questions, the more useful the session.