Implementing

This is not legal advice.

Seven functional requirements follow from three words. Objective: records made at the time, and actual times rather than confirmed schedules. Reliable: a full change history, no silent overwriting, retention with records producible in order. Accessible: employees see their own records, and export works in a readable form. For an additional implementation-oriented example, see learn more here.

Mobile clock-in, geofencing, task attribution, dashboards and integrations satisfy none of the seven. They may still be worth having; they are not what the standard asks for, and a system chosen on them can fail all seven. For additional workplace and technology context, see Eurofound.

For many employers the whole implementation is a page. A form with four columns, a same-day routine, a weekly ten-minute check by a named person, a place to keep them, and a corrections rule. The weekly check is what converts a pile of forms into a system, and it is the part omitted.

Corrections are ordinary and how they are made decides everything. Never overwrite; record who, when and why. One erased and rewritten figure gives an inspector reason to doubt the whole file, and a struck-through entry with an initial strengthens it. For additional workplace and technology context, see Harvard Business Review.

Where a works council exists, involve it early. The decision that created the duty was itself a works council case, and late involvement means a supplier's defaults have already answered the questions the council would have raised.

Remote and mobile work need decisions made in advance. When the day starts for somebody travelling from home, whether travel between jobs counts, how waiting and standby are treated — each has money attached, and inconsistency is what gets noticed rather than the answer itself.

• Correcting a Record

  Corrections are ordinary and necessary. How they are made is what decides whether the whole file survives scrutiny.

• Data Protection

  A legal duty to record is a lawful basis to process, and it does not extend to everything a system can collect.

• Field Staff and Drivers

  Mobile work is where recording is hardest and where the boundary questions have real money attached. Four of them, decided in advance.

• Home Office and Flexibility

  Remote work is where the duty is most often assumed not to apply, and where the rest-period question it exists for is sharpest.

• Migrating From Paper

  The old records stay, the new system starts clean, and the temptation in between is the one that creates a real problem.

• Small Employers

  Under twenty people the whole thing is an afternoon and ten minutes a week. What to do, in order, starting today.

• What a System Has to Do

  Seven functional requirements derived from three words, and the features that appear on every product page and satisfy none of them.

• What Auditors Ask For

  Six requests, in the order they usually come, and the two answers that turn a routine check into a longer one.

• Who Does the Recording

  All three are permitted and the responsibility does not move. What each arrangement is good at, and where each one fails.

• Without Buying Software

  A form, a routine and a weekly check satisfy the duty for a small employer. What the whole implementation actually looks like.

• Works Councils

  The decision that created the duty was itself a works council case. What that means for whether, how, and what gets recorded.