Works Council & Privacy Pack
Deskletics for Teams is designed so that a works council can approve it without a fight: participation is opt-in per employee, admins never see health data, and aggregates only appear for groups of five or more. This document lays out exactly how — data inventory, consent model, legal bases, hosting, retention, and suggested wording for a works agreement.
Last updated: 9 June 2026
Download this pack as a PDF to share with your works council, data protection officer, or HR. Questions or a walkthrough call: hello@deskletics.app.
1. What Deskletics is
Deskletics gives desk workers short, guided movement breaks (20 seconds to 7 minutes) timed around their real workday — it steps aside for meetings and catches the afternoon slump. Employees use it privately, like any personal wellbeing tool. The employer’s team plan adds seat licensing and an activation dashboard whose entire purpose is answering one question: “is the benefit we pay for being used?” — not “what is employee X doing?”.
2. Data inventory
Data Deskletics processes for an employee account
| Data | Purpose |
|---|---|
| Email address, display name (optional), hashed password | Account sign-in. Passwords are never stored in plain text. |
| Break preferences (working hours, cadence, focus areas, session length) | Personalising when and what to suggest. Visible only to the employee. |
| Completed sessions (time, duration, optional one-tap 'how it felt') | The employee's own progress view and gentle difficulty adaptation. |
| Web-push subscription (if reminders are enabled) | Delivering break reminders. Optional, revocable in one tap. |
| Calendar busy/free windows (only if the employee connects a calendar) | Skipping reminders during meetings. Event titles, attendees and notes are never stored. |
Data Deskletics never collects
| Never collected | Why it matters |
|---|---|
| Health, medical, biometric or fitness-tracker data | There is nothing health-related for anyone to see — by design, not by policy. |
| Mood, stress scores, wellbeing assessments | Session feedback is a preference about exercise difficulty, not a psychological measurement. |
| Keyboard, screen, location or activity monitoring | Deskletics has no technical capability to observe work behaviour. |
| Calendar contents (titles, participants, notes) | Only busy/free time windows are derived, to avoid interrupting meetings. |
3. What a team admin can see — and can never see
Default: nothing individual. Every member’s participation visibility starts off. Until an employee actively opts in, the admin dashboard shows only their name, role and join date.
- If (and only if) an employee opts in, an admin can see that member’s participation: session counts, minutes, current streak, last-active date and preferred focus areas. Opt-in is a single toggle in the employee’s own settings and can be revoked at any time, with immediate effect.
- Aggregate team trends are cohort-gated: org-wide breakdowns appear only when at least five members have opted in, so small-team aggregates cannot be traced back to individuals.
- Never visible to any admin, opt-in or not: health-related settings (e.g. the employee’s contraindication selections), session feedback, reminder interactions (who snoozed or skipped), calendar information, or any content of the employee’s personal preferences.
4. Why this is not performance monitoring
Tools capable of monitoring employee behaviour or performance are rightly subject to co-determination (in Germany, § 87 (1) No. 6 BetrVG; comparable rules exist in Austria under § 96 ArbVG). Deskletics is built to minimise exactly that concern:
- Participation data exists only with the employee’s individual, revocable consent.
- The data that exists (break counts and minutes) has no plausible performance interpretation — it measures use of a benefit, not output, presence or productivity.
- There is no export of individual histories, no alerting on inactivity, and no ranking of employees.
- Opting out (or never opting in) is invisible in aggregates and carries no flag an admin can act on.
This document describes the product truthfully but is not legal advice; whether and how co-determination applies is for the parties and their counsel to assess.
5. Legal bases (GDPR)
| Processing | Legal basis |
|---|---|
| Account, preferences, session history | Art. 6(1)(b) — performance of the user agreement with the employee. |
| Participation visibility to team admins | Art. 6(1)(a) — the employee's explicit, revocable opt-in consent. |
| Break reminders (web push), calendar connection | Art. 6(1)(a) — consent via browser permission / explicit connection. |
| Seat billing, invitations, company administration | Art. 6(1)(b)/(f) — contract with the company; legitimate interest in administering it. |
The full picture, including data-subject rights and the controller’s identity, is in our Privacy Policy.
6. Hosting and processors
- Hosting & database: EU (Germany), Hetzner Online GmbH.
- Email delivery: EU-hosted SMTP, used for invitations and account/billing notices only.
- Payments: Stripe processes the company’s billing; employees’ personal data is not shared with Stripe.
- Web push: delivered through the employee’s own browser vendor (Google, Mozilla, Apple), which receives the technical push endpoint only.
- No advertising or third-party tracking. The marketing site offers optional, anonymous first-party statistics — off by default, irrelevant to app usage.
7. Retention and deletion
- Account data lives for the life of the account and is deleted with it.
- Reminder delivery logs are pruned after 7 days.
- Anonymous marketing-site statistics are deleted after at most 13 months.
- When an employee leaves the team, the company link is removed; their personal progress stays theirs, on a free personal account.
- Deletion requests: hello@deskletics.app — handled under the GDPR rights described in the Privacy Policy.
8. Suggested wording for a works agreement
If the parties choose to record the arrangement, the following clause reflects how Deskletics actually behaves and can serve as a starting point:
“The employer provides Deskletics as a voluntary wellbeing benefit. Use is optional and has no bearing on performance assessment. The employer receives individual participation data (session counts, minutes, streak, focus areas) only for employees who have actively enabled visibility in their own settings; this consent is revocable at any time with immediate effect. Aggregated statistics are displayed only for groups of at least five consenting employees. Health-related data is neither collected nor displayed. The employer will not use Deskletics data for performance monitoring, disciplinary measures, or attendance control.”
9. Frequently asked by works councils
Can the employer see who is not using it? Only opted-in members appear with participation data. Members who never opt in are indistinguishable from members who opted in but happen to be inactive — there is no “refused consent” flag.
Can consent be made a condition of employment or bundled into onboarding? It shouldn’t be, and the product doesn’t push it: visibility defaults to off and the app never nags employees to enable it.
Where is the data? EU (Germany). No transfers outside the EU are required for normal operation; the exceptions (browser push vendors, optional Google sign-in) are listed in the Privacy Policy with their safeguards.
Can we trial it first? Yes — pilots are the normal path. Write to hello@deskletics.app and we’ll set one up, including a session with your works council or DPO if helpful.
10. Contact
PS New Media (owner: Paolo Schmidt) · Ulrich-Schreier-Straße 17, 5020 Salzburg, Austria · hello@deskletics.app. See also: Privacy Policy · Imprint · Deskletics for Teams.