Germany, Sweden and co-determination
The conversation with your works council.
A tool that records and analyses employee meetings is a co-determination matter. This page is the information you need to run that process — not a claim that it does not apply.
Germany
Introducing a technical system capable of monitoring employee performance or behaviour engages works-council co-determination under §87(1)(6) of the Betriebsverfassungsgesetz. Our position is that this applies to our product and that the employer should expect to negotiate an agreement before deployment, not after.
The five questions a Betriebsrat asks first
- “Can a manager see how an individual performed?” No. The personal read is readable only by the person it is about. Two of the four layers enforcing that are in the database itself — a row policy that admits only the subject, with no administrative path, and a column-level revoke on the legacy fields — and two are in the application. Managers and workspace admins have no path to it, and neither do we. There is one limit on this, and it is the employer-mailbox route named in the gaps below. The shared meeting report describes the conversation and names functions and interfaces, not individual performance.
- “Is it covert?” No. The notetaker appears in the participant list as notetaker@unseendynamics.ai, described as Unseen Dynamics — transcribing & analysing. The host must confirm, before every capture, that they will inform every participant and give them a real chance to decline. There is a public notice page for participants with no account.
- “Can someone refuse?” Yes, four ways: exclude a specific meeting before it starts, remove the notetaker mid-call, pause capture for the entire workspace, or submit an erasure request directly to us without an account.
- “Does it rank or score people?” No. There is a rule inside the method that forbids reporting or implying how anyone felt, and requires structural conditions instead. Output is per-relationship and per-function, and there is no individual scoring surface, league table or trend-per-person view.
- “Where does the data go?” Audio is transcribed on hardware we operate in the EU — there is no third-party transcription service. Database and application are in Frankfurt. The full list is on the sub-processors page.
What the employer still has to decide
These are not ours to answer, and a works council will expect the employer to have a position on each: which meetings are in scope and which are excluded outright; how participants are informed, and in what language; what happens when someone declines; who in the organisation holds the organisation-view grant, and on what basis; and how long the employer intends to keep transcripts, given that the host controls them.
What we cannot promise yet
- A hard six-month limit for meetings captured before 26 August 2026. The automatic sweep runs daily and deletes the copy in your workspace together with the copy on our transcription machine; immediate deletion on request also works. The machine copy is deleted by an exact per-meeting pointer, and that pointer has only been recorded since 26 August 2026 — every capture since then carries one. For meetings captured before that date it has to be established by hand, one at a time, and most of them have not been done. No copy on that machine is yet six months old, so none has outlived the published period; on current holdings the first falls due in January 2027, and the pairing has to be finished before then. If you ask about a specific meeting from before 26 August we will tell you what we can see, which for most of them is that we cannot yet identify the machine copy. For an agreement that requires an evidenced hard limit, that is the population to carve out.
- “Your employer can never reach your personal read.” We do not say that, and a works council should not be told it. An employer who controls the mailbox a person signs in with can request a sign-in link and sign in as them. That route closes only once the person has set their own credential, and until then the mailbox is the credential. The four layers stop a manager, a workspace admin and us; they do not stop whoever holds the mailbox.
- Removing one person's words from everything. A participant's contributions can appear in the memo, in the host's report and in other people's personal reads. Clean per-speaker redaction across all three is unsolved.
- A certification. We hold no SOC 2 and no ISO 27001.
- A published EU AI Act classification of our own system. Not yet written down.
We would rather you take those five into the room with you than discover them in month three.
Sweden
Introducing a system of this kind is normally a matter for negotiation with the union under §11 of the Medbestämmandelagen before the decision is implemented. The five answers above are the same, and the same five gaps apply.
Elsewhere
Estonia, Finland, Norway, Denmark, the Netherlands and the UK each have their own consultation and data-protection expectations. Two points are general. Consent under the GDPR must be freely given, specific and informed — which is why the host attestation is explicit and why the notice exists. And where any participant sits in an all-party-consent jurisdiction, our own interface tells the host to treat the whole meeting as all-party and not to capture when unsure.