White paper for HR, Privacy & Works Council
The Works Council Is Watching: Good.
Which data a learning platform needs, what it should never collect, and what a works agreement looks like that brings protection and training together.
The problem this is about
A learning platform is a technical system objectively capable of recording behaviour and performance, which brings co-determination under Sec. 87 of the German Works Constitution Act into play. Treat that as a formality and you lose months. Take the questions seriously and you gain an ally.
The three worries are always the same: can my manager see how long I took? Where is the data stored? And what happens after the click in a phishing simulation? This paper answers all three: concretely enough to turn straight into a works agreement.
What is inside
- The data minimum: the four things training evidence needs, and the list of what is off limits
- Phishing simulation as training, not a trap: the ground rules that build trust
- Eight cornerstones for the works agreement: walkable in a single meeting
- How ConformBase delivers on the promises technically (data minimisation, no tracking in the learning area, aggregated reporting)
Built to be forwarded: to the works council, the data protection officer, or to the management that has to convince both. Which is why there is no form; it downloads directly.
Download directly: no form
This paper is built to be forwarded, to the works council, the data protection officer or the management. That is why it does not ask for an e-mail address.
- 7 pages
- As of August 2026
All papers provide general information and are not legal advice.