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Module 2 of 5 · Working time records · Block 2

What exactly must be logged

The rule says little, which is why it gets misread in both directions: some record too little, and some build a surveillance system nobody asked them for.

Content reviewed on

The minimum content

The specific start time and the specific end time of the working day, each day and for each worker. That is what article 34.9 requires.

Neither location, nor the activity performed, nor productivity form part of the mandatory record. Adding them is a company decision and must be justified under the GDPR.

Breaks

The Statute does not require logging breaks, but it does require effective working time to be correct. If the collective agreement does not count the meal break as working time, logging it is the only way for the effective hours to add up.

On split shifts, the usual approach is to log each stretch with its own entry and exit.

What should stay out

A working-time record is not a performance monitoring system. Cross-referencing it with data that does not serve its purpose — permanent geolocation, screenshots, keystroke activity — moves the processing onto ground that requires different safeguards.

What an auditor usually asks for

  • Start and end times recorded precisely, not rounded away
  • A clear criterion on which breaks are logged and why
  • Data limited to the purpose: no disguised performance monitoring
  • Prior information to staff about what is recorded

How the record content is configured in Kimobox

  1. 1Define the punch types you need: entry, exit and breaks, according to the collective agreement.
  2. 2Set the rounding tolerance, if any, and document it.
  3. 3Inform staff of the scope of the record from the portal itself, with a read receipt.

Recording too much is as problematic as recording too little: the GDPR minimisation principle applies here too.

See the available clock-in channels

Where each figure comes from

References to the official text in force. If a standard is revised, this page is updated and the review date says so.

  1. Real Decreto-ley 8/2019 on urgent social protection measures and working time BOE-A-2019-3481 · 12/03/2019
  2. Estatuto de los Trabajadores (Royal Legislative Decree 2/2015), arts. 34, 35 and 37 BOE-A-2015-11430 · —
  3. Royal Legislative Decree 5/2000 (LISOS), arts. 7.5 and 40.1.b) BOE-A-2000-15060 · —
  4. Law 10/2021 of 9 July on remote working BOE-A-2021-11472 · 10/07/2021
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