At the recent EyeWarn stakeholder event, participants were split into three focus groups to discuss a scenario set in a near-future workplace, where worker wellbeing and productivity are supported through advanced biometric technologies.

This focus group consisted of workers and those in human resources roles.

Two round tables with four people sitting at each one. The tables have papers and cups on them. A man holding a microphone is standing to the right smiling at the camera.

Scenario

A mid-sized logistics company has implemented an eye-tracking fatigue detection system across its workforce, including office staff, warehouse operatives, and long-haul drivers. The company reports improvements in safety metrics and reduced accident rates. However, employee reactions are mixed. Some workers appreciate the proactive support for wellbeing, while others express concerns about surveillance, data use, and potential disciplinary consequences. Trade unions and regulators are beginning to take interest, and the company is considering scaling the system across multiple regions. The company needs expert perspectives to evaluate the broader implications of this technology.

Discussions

Regulatory framework needs

Participants agreed that current regulatory frameworks are insufficient for governing biometric technologies of this kind. Eye-tracking data was viewed as highly sensitive, with the potential to reveal health, stress, and neurological information. Many argued it should be classified as high-risk data requiring stronger protections.

There was strong support for restricting employer access to individual-level data. Its use in performance management, hiring, dismissal, or insurance decisions was widely seen as inappropriate. Clear rules would also be needed around data storage, retention, and deletion.

Fatigue was recognised as influenced by factors beyond work, such as health, commuting, and caregiving. Using fatigue data in workplace decisions could therefore lead to indirect discrimination, highlighting the need for safeguards.

Data privacy, consent, and ownership

Consent was widely viewed as problematic in workplace contexts. Even when participation is presented as voluntary, workers may feel unable to refuse due to job insecurity or workplace culture, undermining meaningful consent.

Participants emphasised that individuals should retain ownership and control of their biometric data, including how it is stored and shared. Local storage on personal devices was preferred over centralised employer systems.

The risks of data breaches were also highlighted. Past incidents involving sensitive data demonstrate the potential for harm, reinforcing the need for strong protections.

Privacy was also seen as a collective issue. Even anonymised data can enable inferences about individuals or groups, raising concerns about indirect identification and misuse.

Standards, certifications, and technical reliability

Fatigue was described as complex and context-dependent, making it difficult to measure accurately. Participants stressed the need for independent validation, certification, and sector-specific standards before deployment.

Environmental factors such as lighting, movement, and screen use may affect system accuracy. Fixed fatigue thresholds were seen as potentially unfair, given individual differences.

Misclassification was identified as a key risk. Some individuals may appear fatigued without reduced performance, while others may perform effectively despite fatigue. This raises concerns about both false positives and false negatives, especially if data informs workplace decisions.

Labour laws, rights, and liability

Fatigue monitoring raises questions about responsibility and liability. If fatigue is detected but no action is taken, it is unclear whether accountability lies with the employer or the worker.

Participants were concerned that such systems could weaken labour protections by enabling new forms of monitoring or justification for disciplinary action. Employers may also rely on monitoring to demonstrate compliance without addressing underlying issues such as workload or staffing.

Monitoring fatigue may extend workplace oversight into private life, as fatigue is shaped by factors outside work. Employer incentives were also noted, as organisations may avoid systems that expose structural problems or require costly changes.

Benefits, risks, and acceptability

Some benefits were identified, particularly in high-risk sectors such as healthcare, construction, and transport. These include improved safety and earlier detection of fatigue-related risks. Individuals may also value such tools for personal use.

However, risks were considered significant, including increased surveillance, reduced autonomy, and potential discrimination. Continuous monitoring may alter behaviour, leading to self-censorship and reduced trust.

Participants noted that fatigue monitoring does not address root causes such as long hours or understaffing, risking a superficial solution. Psychological impacts were also raised, as constant feedback may increase stress and anxiety.

Acceptability would depend on strict conditions: full worker control over data, no employer access to identifiable individual data, and use limited to safety or wellbeing purposes. There was also support for collective approaches, such as using aggregated data through trade unions to identify unsafe conditions while protecting privacy.

Unintended consequences

Potential unintended consequences included workers concealing fatigue to avoid negative outcomes and behavioural changes due to constant monitoring. There was concern that organisations may prioritise monitoring over improving working conditions.

Frequent fatigue alerts may also increase anxiety, particularly where workers have limited control over schedules or workload.

Reflections and conclusion

Participants expressed a largely sceptical view of workplace fatigue monitoring. Most would oppose its use in its current form, citing concerns about surveillance, data misuse, and unequal power dynamics.

There was some conditional acceptance in high-risk sectors, but only with strong safeguards, including worker control over data and clear legal protections. Trust emerged as a central issue.

Overall, participants emphasised that fatigue is primarily driven by structural factors. Improving working conditions was seen as a more effective and ethical approach than introducing additional monitoring technologies.