The Department of Labor is expected to revise its template notice to match the new requirements, and that updated template is still pending. Employers that relied on the old template will need to confirm it no longer satisfies the statute before using it.
For employers, the task is a location-by-location audit. Identify every place monitoring occurs, update handbooks and posted notices to name those places, and make sure new-hire paperwork covers prohibited conduct and monitored activities. Two exceptions matter. Security monitoring in common areas held out for public use is excluded from the definition of electronic monitoring. Employers may also monitor without prior notice when they reasonably believe an employee is violating the law, violating others' legal rights, or creating a hostile workplace, and the monitoring may produce evidence of that conduct. Document the basis for any notice-free monitoring. Connecticut is one of several states with notice or consent rules for workplace monitoring, so this change is part of a broader trend that multistate employers should track.