May employees be recorded by the robot?

Only under strict conditions and never for monitoring of conduct or performance.

The legal basis is generally legitimate interest under Art. 6(1)(f) GDPR. This requires a balancing of interests, which must be documented.

Proven in practice: inspection rounds at unstaffed times, technical blurring of persons, clear purpose limitation in the works agreement. Where recordings are unavoidable, the retention period should be kept short.

What belongs in the works agreement on this point is set out under What belongs in a works agreement on robot deployment?.