"The nature and scope of modern technology poses a growing threat to employee privacy in the workplace and, as a result, presents new challenges and a greater need for clearer rules and boundaries for both actors in the workplace: the employer and the employee. This article focuses on various aspects of surveillance and monitoring of employees regarding the internet, e-mail, phone calls and location data. It examines the problems and conflict of interests that arise and outlines various legal responses in hard law and soft law, including legal rulings. Different approaches to these topics are presented, mainly the approach of the American legal system versus the European ones, and some examples of cases in various countries are considered. It is argued that by learning from each other and the various solutions adopted, we should strive to preserve, as far as possible, the employee's right to privacy."

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