Agent skill

Employee Surveillance Dpia

by mukul975 in mukul975/Privacy-Data-Protection-Skills

Guides DPIA for workplace monitoring including email surveillance, internet usage monitoring, CCTV, GPS tracking, and keystroke logging.

Apache-2.0Auto-check passedLegal & Compliance

Install Employee Surveillance Dpia

skills CLI
$ npx skills add mukul975/Privacy-Data-Protection-Skills --skill employee-surveillance-dpia -a claude-code

Project install by default; add -g for ~/.claude/skills/.

GitHub CLI
$ gh skill install mukul975/Privacy-Data-Protection-Skills employee-surveillance-dpia --agent claude-code

Project scope by default; add --scope user for a personal install. Needs GitHub CLI 2.90.0 or later (public preview).

Manual copy
$ git clone --depth 1 https://github.com/mukul975/Privacy-Data-Protection-Skills.git skills-src && mkdir -p .claude/skills && cp -r skills-src/skills/privacy/employee-surveillance-dpia .claude/skills/employee-surveillance-dpia && rm -rf skills-src

Use ~/.claude/skills/ instead of .claude/skills for a personal install. The folder must contain SKILL.md.

Claude Code skills documentation · loads skills from .claude/skills/

Facts

Skill name
employee-surveillance-dpia
GitHub stars
301
Token cost
~3.3k tokens
SKILL.md length
1,399 words
Files
5 (incl. scripts, references, assets)
Skills in repo
280
Repo updated
First seen
Licence
Apache-2.0

At a glance

Guides DPIA for workplace monitoring including email surveillance, internet usage monitoring, CCTV, GPS tracking, and keystroke logging.

  • Works in 5 steps: Monitoring Justification (Week 1) → Proportionality Balancing (Week 2) → Employee Consultation and Transparency… → …
  • Tasks that involve Privacy and GDPR
  • SKILL.md covers Overview, Legal Framework, Monitoring Types and… and DPIA Methodology for Employee…, plus 1 more section
  • Runs Python scripts from its folder

What it does

Employee Surveillance Dpia is an agent skill from mukul975/Privacy-Data-Protection-Skills. Guides DPIA for workplace monitoring including email surveillance, internet usage monitoring, CCTV, GPS tracking, and keystroke logging. Covers GDPR Art. 88 employment context provisions, WP29 Opinion 2/2017 on data processing at work, and proportionality balancing for employee monitoring. Keywords: employee surveillance, workplace monitoring, DPIA, Art. 88, WP29 Opinion 2/2017, CCTV, email monitoring, GPS tracking.

Its SKILL.md is about 3.3k tokens, which your agent loads only when the skill is triggered. The skill folder holds 7 other files, including scripts, reference files and assets (for example `assets/template.md`, `references/standards.md` and `references/workflows.md`).

It sits in Legal & Compliance, covering Privacy and GDPR. The repository describes itself as: 282+ structured privacy & data protection skills for AI agents. GDPR, CCPA, EU AI Act, HIPAA, LGPD, PIPL, DPDP Act. The licence is Apache-2.0.

When your agent uses it

  • Tasks that involve Privacy and GDPR

Example prompts

  • “Use the employee-surveillance-dpia skill to guide DPIA for workplace monitoring including email surveillance, internet usage monitoring, CCTV, GPS…”
  • “/employee-surveillance-dpia”

Requirements

  • Python 3

Workflow steps

5 steps, taken from the step headings in SKILL.md.

  1. Monitoring Justification (Week 1)
  2. Proportionality Balancing (Week 2)
  3. Employee Consultation and Transparency (Week 3)
  4. Risk Assessment (Week 3-4)
  5. Mitigation and Approval (Week 4-5)

What it can do on your machine

Read from SKILL.md and the folder at commit 9b2ef9e. It shows what the files ask for, not the result of running them.

  • Tool permissions

    Pre-approves nothing: there is no allowed-tools line, so your agent's usual permission prompts apply.

    From allowed-tools in the SKILL.md frontmatter.

  • Runs code

    Ships 1 file in scripts/ (Python), which the agent can run.

    From the folder's file list and the shell code blocks in SKILL.md.

  • Network

    No URLs in SKILL.md.

    From URLs in SKILL.md, links to its own repository left out.

  • Credentials

    Names no API keys, tokens, secrets or passwords.

    From names ending in _API_KEY, _TOKEN, _SECRET, _KEY or _PASSWORD in SKILL.md.

Context cost

Employee Surveillance Dpia loads about 3.3k tokens when it runs, and up to ~5k if it reads all its reference files. Until then it costs about 112 tokens; SKILL.md has 1,399 words of instructions outside code blocks.

Always · name and description, kept in context so the agent knows when to use it
~112
When it runs · the whole SKILL.md, loaded when a task matches
~3.3k
With references · SKILL.md plus every file in references/, read only if the agent opens them
~5k

Estimates: characters ÷ 4, the usual rule of thumb; real counts depend on the model's tokenizer. Scripts and assets cost tokens only if the agent reads them.

Safety

Auto-check passed

The automated check found no risky patterns in SKILL.md.

Automated static check — not a guarantee. Review scripts before installing. It scans the text of SKILL.md for risky patterns (piping downloads into a shell, reading credential files, hidden Unicode, destructive commands); the scripts in this folder are not scanned.

SKILL.md

The full file from mukul975/Privacy-Data-Protection-Skills at commit 9b2ef9e, republished under its Apache-2.0 licence (© mukul975). 1,399 words, ~3,347 tokens.

Download SKILL.mdSave it as .claude/skills/employee-surveillance-dpia/SKILL.md (or your agent's skills folder). This skill also uses 4 other files; get the full folder from GitHub.
name
employee-surveillance-dpia
description
Guides DPIA for workplace monitoring including email surveillance, internet usage monitoring, CCTV, GPS tracking, and keystroke logging. Covers GDPR Art. 88 employment context provisions, WP29 Opinion 2/2017 on data processing at work, and proportionality balancing for employee monitoring. Keywords: employee surveillance, workplace monitoring, DPIA, Art. 88, WP29 Opinion 2/2017, CCTV, email monitoring, GPS tracking.
license
Apache-2.0
metadata.author
mukul975
metadata.version
1.0
metadata.domain
privacy
metadata.subdomain
privacy-impact-assessment
metadata.tags
employee-surveillance, workplace-monitoring, dpia, art-88, gps-tracking, cctv

Assessing Employee Surveillance Privacy

Overview

Workplace monitoring represents one of the most sensitive areas of data protection because of the inherent power imbalance between employer and employee. GDPR Art. 88 allows Member States to provide more specific rules for processing in the employment context, and WP29 Opinion 2/2017 on data processing at work provides detailed guidance on proportionality, transparency, and data minimisation for employee monitoring. This skill provides a DPIA methodology for all forms of workplace surveillance: email monitoring, internet usage tracking, CCTV, GPS vehicle and personnel tracking, keystroke and screen capture logging, telephone call monitoring, and wearable device monitoring.

GDPR Art. 88 — Processing in the Employment Context

Art. 88(1) permits Member States to provide, by law or collective agreement, more specific rules for processing in the employment context, covering recruitment, performance of the employment contract, management, planning and organisation of work, equality and diversity, health and safety, protection of employer's property, and exercise of employment-related rights.

Art. 88(2) requires that such rules include suitable and specific measures to safeguard the data subject's human dignity, legitimate interests, and fundamental rights, with particular regard to transparency, intra-group transfers, and monitoring systems in the workplace.

WP29 Opinion 2/2017 on Data Processing at Work

Key principles established:

PrincipleApplication to Workplace Monitoring
NecessityMonitoring must be strictly necessary for the stated purpose; less intrusive alternatives must be evaluated first
Purpose limitationData collected for security monitoring cannot be repurposed for performance management without separate justification
Data minimisationMonitoring should capture the minimum data necessary — metadata over content, aggregate over individual
TransparencyEmployees must be clearly informed about the nature, scope, and purpose of monitoring before it begins
ProportionalityThe intrusiveness of monitoring must be proportionate to the legitimate interest pursued; blanket monitoring is rarely proportionate
Consent limitationsEmployee consent is generally not a valid lawful basis due to the power imbalance; legitimate interest (Art. 6(1)(f)) is more appropriate but requires rigorous balancing
National Employment Data Protection Laws
CountryLegislationKey Provisions
GermanyBDSG Section 26Employee data processing only lawful when necessary for the employment relationship. Works council co-determination right (BetrVG Section 87(1)(6)) for technical monitoring equipment.
FranceLabour Code L1121-1, L1222-4Proportionality and transparency requirements. CNIL Guidance on employee monitoring (2020). Prior works council consultation required.
ItalyWorkers' Statute Art. 4Remote surveillance equipment prohibited unless agreed with trade unions or authorised by labour inspectorate.
SpainLOPDGDD Art. 87-91Specific provisions for digital rights in the workplace, including right to digital disconnection.
NetherlandsUAVG Implementation ActWorks council consent required for employee monitoring systems per WOR Art. 27(1)(l).

Monitoring Types and Proportionality Assessment

Email Monitoring
AspectAssessment
Legitimate purposesRegulatory compliance (FCA SYSC 10A, MiFID II), insider threat detection, intellectual property protection, harassment prevention
Proportionality levelsMetadata only (sender, recipient, timestamp) < Subject line + metadata < Full content scanning < Real-time content review
Data minimisationMetadata monitoring is significantly less intrusive than content review; content should only be accessed with specific justification
TransparencyEmployees must be informed of the scope of email monitoring in the privacy notice and employment contract
Private useIf employer permits private email use, monitoring must not extend to private communications; separation mechanisms should be implemented
RetentionEmail monitoring data should have shorter retention than business email retention; monitoring metadata should be deleted within 30-90 days
Internet Usage Monitoring
AspectAssessment
Legitimate purposesNetwork security (malware prevention), bandwidth management, acceptable use enforcement, regulatory compliance
Proportionality levelsCategory-level monitoring < Domain-level logging < Full URL logging < Content inspection (DPI)
Data minimisationCategory-level classification is proportionate for most purposes; URL-level logging requires specific justification
TransparencyEmployees must be informed of what is monitored and any automated blocking
Personal browsingIf personal internet use is permitted, monitoring should not capture personal browsing details; automatic exclusion of personal browsing categories where feasible
CCTV Workplace Monitoring
AspectAssessment
Legitimate purposesPhysical security, health and safety, theft prevention, regulatory compliance
Proportionality levelsExternal perimeter only < Reception and entry points < Common areas (excluding toilets, break rooms, changing areas) < Individual workstations
Prohibited areasToilets, changing rooms, break rooms, and prayer rooms must never be monitored by CCTV
Covert monitoringOnly permissible in exceptional circumstances (suspected criminal activity) for a limited period, with prior DPO approval and legal counsel sign-off
RetentionMaximum 30 days unless footage is required for a specific investigation; automated deletion
Audio recordingGenerally disproportionate in the workplace; separate justification required
GPS and Location Tracking
AspectAssessment
Legitimate purposesFleet management, delivery route optimisation, lone worker safety, vehicle theft prevention
ProportionalityGPS tracking of company vehicles during working hours is generally proportionate; continuous tracking outside working hours is disproportionate
Data minimisationTracking frequency should be proportionate (periodic location updates vs continuous tracking); geofencing (alerts on boundary crossing) is less intrusive than continuous tracking
Personal vehiclesGPS tracking of employees' personal vehicles is highly intrusive and rarely proportionate
Working hours onlyGPS tracking should automatically deactivate outside working hours or when vehicle is used for personal purposes (if permitted)
Show full SKILL.md (578 more words)Show less
Keystroke and Screen Capture Logging
AspectAssessment
Legitimate purposesInsider threat detection in high-security environments, fraud investigation
ProportionalityKeystroke logging is one of the most intrusive forms of monitoring — captures personal passwords, private messages, health searches, and intimate communications
RecommendationGenerally disproportionate for routine monitoring; may be justified only in specific high-risk roles (financial traders, classified information handlers) with strict access controls and short retention
DPO and WP29 positionWP29 Opinion 2/2017 states that technologies that monitor keystrokes or capture screenshots are very intrusive and should be considered a last resort

DPIA Methodology for Employee Surveillance

Phase 1: Monitoring Justification (Week 1)
  1. Document the specific, legitimate purpose for each monitoring type.
  2. Assess whether the monitoring is necessary for the stated purpose or whether less intrusive alternatives exist.
  3. Conduct an Art. 6(1)(f) legitimate interest assessment (LIA) for each monitoring type:
    • Controller's legitimate interest: what interest is being protected?
    • Necessity: is monitoring necessary to achieve the interest?
    • Balancing: do the employee's rights and freedoms override the legitimate interest?
  4. If using Art. 6(1)(c) legal obligation as lawful basis, identify the specific legal requirement (e.g., FCA SYSC 10A.1 for financial services communications recording).
Phase 2: Proportionality Balancing (Week 2)

For each monitoring type, apply the proportionality framework:

START: Proposed monitoring measure
│
├─ Is the monitoring measure necessary for the stated purpose?
│  ├─ NO → Monitoring is not justified. Remove from scope.
│  └─ YES → Continue.
│
├─ Could a less intrusive measure achieve the same purpose?
│  ├─ YES → Adopt the less intrusive measure instead.
│  └─ NO → Continue.
│
├─ Is the scope of monitoring proportionate?
│  ├─ Blanket monitoring of all employees?
│  │  └─ Generally disproportionate. Target monitoring to specific roles or risk areas.
│  ├─ Continuous monitoring during all working hours?
│  │  └─ Consider periodic or event-triggered monitoring instead.
│  └─ Monitoring extends to personal/private activity?
│     └─ Disproportionate. Implement exclusion mechanisms.
│
├─ Is the retention period proportionate?
│  ├─ Monitoring data retained indefinitely?
│  │  └─ Disproportionate. Set specific retention periods with automated deletion.
│  └─ Retention aligned with the monitoring purpose?
│     └─ Document justification for retention period.
│
└─ END: Document the proportionality assessment for each monitoring type.
Phase 3: Employee Consultation and Transparency (Week 3)
  1. Prepare employee privacy notice covering monitoring scope, purposes, and rights.
  2. Consult works council or employee representatives (mandatory in many jurisdictions):
    • Germany: BetrVG Section 87(1)(6) co-determination right
    • France: Prior consultation with CSE (Comite Social et Economique)
    • Netherlands: Works council consent under WOR Art. 27(1)(l)
  3. Seek data subject views per Art. 35(9) through works council consultation.
  4. Update employment contracts and acceptable use policies.
Phase 4: Risk Assessment (Week 3-4)

Assess monitoring-specific risks:

RiskDescription
Chilling effectEmployees modify legitimate behaviour due to awareness of monitoring, reducing creativity, communication, and wellbeing
Discriminatory applicationMonitoring applied more intensively to certain employee groups based on role, location, or other characteristics
Personal data exposureMonitoring captures personal communications, health information, or political/religious content
RepurposingData collected for security used for performance management or disciplinary purposes
Excessive accessLine managers or HR accessing individual monitoring data without justification
Psychological harmContinuous monitoring causing stress, anxiety, and reduced job satisfaction
Phase 5: Mitigation and Approval (Week 4-5)
  1. Implement technical and organisational measures to mitigate identified risks.
  2. Obtain DPO advice per Art. 35(2).
  3. Obtain works council agreement (where required).
  4. Senior management approval.
  5. Register DPIA and schedule review (6 months for employee monitoring, given sensitivity).

Enforcement Precedents

  • CNIL vs Amazon France Logistique (2024): EUR 32 million fine for excessive employee surveillance in warehouses — scanner-based monitoring tracking idle time, stowing speed, and time between tasks was disproportionate to productivity management purposes.
  • Italian Garante vs H&M (2020): EUR 35.3 million fine (Hamburg DPA) for systematic recording of private information about employees (health conditions, family problems, religious beliefs) during return-to-work interviews, creating detailed employee profiles.
  • Greek DPA vs PwC Greece (2019): EUR 150,000 fine for unlawful employee email monitoring without adequate legal basis, transparency, or DPIA.
  • Spanish AEPD vs Mercadona (2021): EUR 2.5 million fine for facial recognition of employees and customers — biometric surveillance without DPIA.
  • Romanian DPA vs Raiffeisen Bank (2019): EUR 100,000 fine for GPS monitoring of employees' personal vehicles outside working hours.
  • ECHR Barbulescu v Romania (Grand Chamber, 2017): Established that employee monitoring of communications must meet six criteria: prior notification, extent of monitoring, legitimate justification, less intrusive alternatives, consequences for employee, adequate safeguards.

© mukul975, Apache-2.0. Rendered from Markdown: HTML in the file is shown as text, images as links, and headings moved down two levels. Raw file

Files

SKILL.md and 4 other files (scripts, references, assets) in skills/privacy/employee-surveillance-dpia of mukul975/Privacy-Data-Protection-Skills.

  • SKILL.md
  • assets/template.md
  • references/standards.md
  • references/workflows.md
  • scripts/process.py

Open the folder on GitHubat commit 9b2ef9e

Compare with similar skills

Employee Surveillance Dpia next to the 5 skills that share the most tags, products or categories with it. Stars are the repository's; “used in” counts other GitHub owners with a copy.

Employee Surveillance Dpia compared with similar skills
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Employee Surveillance Dpia this skillmukul975/Privacy-Data-Protection-Skills301—~3.3kAutomated safety check: PassApache-2.0
C15tc15t/c15t1.9k1 repos~1.6kAutomated safety check: PassApache-2.0
HIPAA Safe Harbor Coverage Auditmaziyarpanahi/openmed5.5k—~1.7kAutomated safety check: PassApache-2.0
Korean Privacy Termskimlawtech/korean-privacy-terms587—~2.9kAutomated safety check: PassApache-2.0
Gdpr ComplianceSushegaad/Claude-Skills-Governance-Risk-and-Compliance9461 repos~3.9kAutomated safety check: PassMIT
Hipaa ComplianceSushegaad/Claude-Skills-Governance-Risk-and-Compliance9461 repos~2.3kAutomated safety check: PassMIT

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Questions about Employee Surveillance Dpia

What does Employee Surveillance Dpia do?

Guides DPIA for workplace monitoring including email surveillance, internet usage monitoring, CCTV, GPS tracking, and keystroke logging. Employee Surveillance Dpia is an agent skill from mukul975/Privacy-Data-Protection-Skills. Guides DPIA for workplace monitoring including email surveillance, internet usage monitoring, CCTV, GPS tracking, and keystroke logging.

When should I use Employee Surveillance Dpia?

Employee Surveillance Dpia fits situations like: tasks that involve Privacy and GDPR.

How do I install Employee Surveillance Dpia in Claude Code?

Run `npx skills add mukul975/Privacy-Data-Protection-Skills --skill employee-surveillance-dpia -a claude-code`. Or copy the skill folder (skills/privacy/employee-surveillance-dpia in mukul975/Privacy-Data-Protection-Skills) into .claude/skills/employee-surveillance-dpia in your project. Claude Code loads it when a task matches its description.

How do I install Employee Surveillance Dpia in Codex?

Run `npx skills add mukul975/Privacy-Data-Protection-Skills --skill employee-surveillance-dpia -a codex`. Or copy the skill folder (skills/privacy/employee-surveillance-dpia in mukul975/Privacy-Data-Protection-Skills) into .agents/skills/employee-surveillance-dpia in your project. Codex loads it when a task matches its description.

Can I use Employee Surveillance Dpia in Cursor, Gemini CLI or GitHub Copilot?

Cursor, Gemini CLI, GitHub Copilot and OpenCode also load SKILL.md folders. With the skills CLI, run `npx skills add mukul975/Privacy-Data-Protection-Skills --skill employee-surveillance-dpia -a cursor` (or -a gemini-cli, github-copilot or opencode for the others). To copy it by hand, put the folder in .cursor/skills/employee-surveillance-dpia, .gemini/skills/employee-surveillance-dpia, .github/skills/employee-surveillance-dpia and .opencode/skills/employee-surveillance-dpia in your project.

What does Employee Surveillance Dpia need to run?

Going by SKILL.md and its folder, Employee Surveillance Dpia needs Python for the scripts in its folder. Our summary lists: Python 3.

Does Employee Surveillance Dpia access the network?

SKILL.md contains no URLs. Any network use would come from the scripts or tools the agent runs. This is read from the text; nothing was executed.

Is Employee Surveillance Dpia safe to install?

Our automated static check of SKILL.md found no risky patterns, such as piping downloads into a shell, reading credential files or hidden Unicode. It is not a guarantee. The check reads SKILL.md only: the scripts in the folder are not scanned, so read them before running anything.

What licence does Employee Surveillance Dpia use?

Employee Surveillance Dpia is published under the Apache-2.0 licence (declared in SKILL.md). It allows redistribution, so the full SKILL.md is shown on this page.

How many tokens does Employee Surveillance Dpia use?

About 3.3k tokens (SKILL.md is roughly 13k characters). Agents keep only the skill's name and description in context until a task matches; then they load SKILL.md in full. Its references folder adds about 1.7k tokens, read only when the agent opens those files.

What are the alternatives to Employee Surveillance Dpia?

Skills that share tags, products or a category with Employee Surveillance Dpia: C15t (c15t/c15t, 1.9k stars), HIPAA Safe Harbor Coverage Audit (maziyarpanahi/openmed, 5.5k stars), Korean Privacy Terms (kimlawtech/korean-privacy-terms, 587 stars) and Gdpr Compliance (Sushegaad/Claude-Skills-Governance-Risk-and-Compliance, 946 stars). The comparison table on this page puts their stars, adoption, token cost, safety result and licence side by side.

Who maintains Employee Surveillance Dpia?

mukul975 (a GitHub user) maintains it in mukul975/Privacy-Data-Protection-Skills, which has 301 GitHub stars. The repository holds 280 skills in this directory. The repository was last updated on March 16, 2026.

Source: mukul975/Privacy-Data-Protection-Skills on GitHub. Facts on this page come from the repository at the commit we read; the author's words are quoted as theirs.