Keeping track of employees can be an important part of a compliance program, but complexities arise that require cross-department coordination and deep understanding of numerous privacy limitations and other legal requirements, especially whenthe monitoring is used for purposes beyond security. The second installment of this two-part series provides operational guidance on implementing monitoring programs and navigating contrasting rules in Europe, as well as issues surrounding individual monitoring and data controlled by third parties. The first part tackled the role of data monitoring, effective notice, legal considerations and specific policy considerations. See “Balancing Employment Law Considerations During Corruption Investigations” (Sep. 20, 2017).