Global compliance

One record. Every jurisdiction you employ in.

Working-time law is national, but the underlying question is the same everywhere: can you show, per person per day, how long they worked and who signed it off? Workclave answers that once, from approved sessions, and shapes the output to the regime that applies to you — India's labour codes, the EU Working Time Directive, the UK's WTR, the FLSA, Fair Work, and the rest.

🇮🇳 India🇪🇺 European Union & EEA🇬🇧 United Kingdom🇺🇸 United States🇦🇺 Australia🇦🇪 United Arab Emirates🇸🇬 Singapore🇨🇦 Canada

What holds everywhere

Six properties of the record itself. They do not change when you cross a border — only the export format and the retention window do.

One record, every obligation

Attendance registers, working-time evidence, overtime totals and billing data are all derived from the same approved sessions. No parallel compliance system to maintain by hand.

Collected minimally, on purpose

No screenshots, keystroke logging, webcam capture or continuous location. The record contains what working-time law asks for and nothing that a regulator, works council or employee would make you justify.

Approvals make it defensible

Every session carries who worked, on what, and which manager approved it. That is the difference between a timesheet someone typed up and evidence that survives an audit or a wage claim.

Tamper-evident by default

Edits, approvals and access to payroll-relevant fields are appended to an audit trail rather than overwriting history, so a corrected record still shows what it was corrected from.

Retention you control

Retention windows are configurable per workspace, which matters when the same group owes two years in one country and seven in another.

Residency and paperwork

EU customers are served from Netherlands infrastructure. A DPA is available on every paid plan, with sub-processors documented and access scoped by role.

By jurisdiction

The data-protection statute and the working-time statute are separate obligations in every market, and both land on the same attendance record. Here is how each pair maps to what Workclave produces.

India

A central labour-code layer sitting on top of state-level Shops and Establishments Acts, plus a young data-protection statute that treats employee data as personal data.

Working time & records

Code on Wages 2019, OSH & Working Conditions Code 2020, state Shops and Establishments Acts

Working hours, overtime rate, weekly rest and register formats vary by state, so the same team can owe different registers in Karnataka and Maharashtra.

Data protection

Digital Personal Data Protection Act, 2023

Employers are data fiduciaries for employee records: purpose limitation, minimisation, notice and the ability to answer a data-principal request.

Retention

Attendance registers, wage registers and overtime records, retained for the period prescribed by the applicable central or state rules.

  • Per-session start, stop, break and project records
  • Manager approval recorded against every session
  • Attendance register and timesheet exports (CSV/PDF)
  • Append-only audit trail of edits, approvals and access
  • Attendance register formats aligned to state Shops & Establishments Acts
  • Notice and consent records for employee data, with no biometric capture
  • Data-minimal by design — no screenshots, keystrokes or location trails

European Union & EEA

The strictest combination in our markets: a hard duty to measure daily working time, met without over-collecting personal data.

Working time & records

Working Time Directive 2003/88/EC, as read in CJEU C-55/18 (Deutsche Bank SAE)

Member States must require employers to operate an objective, reliable and accessible system measuring daily working time — 48-hour average weekly limits, 11 hours daily rest and weekly rest are unenforceable without it.

Data protection

GDPR (Regulation (EU) 2016/679)

Employee monitoring needs a lawful basis and proportionality. Screenshot- and keystroke-based tools collect far more than working-time law requires, which is exactly where employers get challenged.

Retention

Daily working-time records per employee, plus opt-out and rest-period evidence. National retention periods apply (Spain: four years).

  • Per-session start, stop, break and project records
  • Manager approval recorded against every session
  • Attendance register and timesheet exports (CSV/PDF)
  • Append-only audit trail of edits, approvals and access
  • Daily working-time records per employee, exportable on request
  • EU data residency (Netherlands) and a signable DPA
  • No surveillance signals collected — nothing to justify to a works council

United Kingdom

Post-Brexit data law that still mirrors the GDPR, paired with working-time and minimum-wage records that are examined together in a dispute.

Working time & records

Working Time Regulations 1998

Adequate records for the 48-hour weekly limit and night-work limits, including a register of workers who have signed an opt-out.

Data protection

UK GDPR & Data Protection Act 2018

The ICO's employment-practices guidance expects monitoring to be necessary and proportionate, with workers told what is collected.

Retention

Working-time records under regulation 9 (two years); National Minimum Wage records must be kept for six years for pay periods from April 2021.

  • Per-session start, stop, break and project records
  • Manager approval recorded against every session
  • Attendance register and timesheet exports (CSV/PDF)
  • Append-only audit trail of edits, approvals and access
  • Hours-worked evidence for NMW and 48-hour-limit questions
  • Retention windows configurable to the longer NMW period
  • Signable DPA and documented sub-processors

United States

No single federal privacy law, but the tightest wage-and-hour record rules — and state biometric statutes that punish over-collection.

Working time & records

Fair Labor Standards Act, 29 CFR Part 516

Non-exempt employees need hours worked each day and each workweek on record. State law layers on more — California pays daily overtime past eight hours and premiums for missed meal or rest breaks.

Data protection

State privacy law (CPRA in California, BIPA in Illinois, and equivalents)

Illinois' BIPA gives employees a private right of action over fingerprint and face-scan capture. A tool that avoids biometric collection removes that exposure entirely.

Retention

Payroll records for three years; time cards, work schedules and wage-computation records for two years.

  • Per-session start, stop, break and project records
  • Manager approval recorded against every session
  • Attendance register and timesheet exports (CSV/PDF)
  • Append-only audit trail of edits, approvals and access
  • Daily and weekly hours per worker, retained past the two- and three-year marks
  • Break and meal-period records tied to each session
  • Email/OTP check-in — no fingerprint or face capture, so BIPA-class exposure never starts

Australia

Prescriptive record-keeping with the longest retention of any market we serve, and penalties that assume the employer can produce records on demand.

Working time & records

Fair Work Act 2009 and Fair Work Regulations 2009

Records must cover ordinary hours, overtime, penalty rates, averaging arrangements and leave — and must be legible, in English and available to a Fair Work Inspector.

Data protection

Privacy Act 1988

The employee-records exemption is narrower than it looks and is under active reform review, so proportionate collection is the safer posture.

Retention

Employee records retained for seven years.

  • Per-session start, stop, break and project records
  • Manager approval recorded against every session
  • Attendance register and timesheet exports (CSV/PDF)
  • Append-only audit trail of edits, approvals and access
  • Ordinary vs overtime hours split by day and pay period
  • Seven-year retention supported without archiving to spreadsheets
  • Inspector-ready exports pulled from the same session data

United Arab Emirates

A recent labour law with mandatory employee-file retention, alongside a federal data-protection law and separate free-zone regimes.

Working time & records

Federal Decree-Law No. 33 of 2021 and Cabinet Resolution No. 1 of 2022

Standard hours, overtime premiums, Friday and public-holiday rules, and part-time or flexible work models that each need their own hours evidence.

Data protection

Federal Decree-Law No. 45 of 2021 (PDPL), plus DIFC and ADGM data-protection laws

Free zones run their own regimes — DIFC and ADGM sit closer to the GDPR than the federal law does, so multi-entity groups usually design to the stricter one.

Retention

Employee files and related records kept for at least two years after the end of employment.

  • Per-session start, stop, break and project records
  • Manager approval recorded against every session
  • Attendance register and timesheet exports (CSV/PDF)
  • Append-only audit trail of edits, approvals and access
  • Overtime and rest-day hours evidence per employee
  • Retention configurable past the end of employment
  • Multi-entity workspaces for mainland and free-zone companies

Singapore

Employment Act record duties written down to the field level, and a data-protection act with a specific employment carve-out.

Working time & records

Employment Act 1968

Part IV workers have statutory hour limits and overtime rates; itemised pay slips must reconcile to recorded hours.

Data protection

Personal Data Protection Act 2012

Collection for managing the employment relationship is permitted without consent, but notification and reasonableness still apply — and breach notification is mandatory.

Retention

Employment records for current employees kept for two years; for former employees, one year after they leave.

  • Per-session start, stop, break and project records
  • Manager approval recorded against every session
  • Attendance register and timesheet exports (CSV/PDF)
  • Append-only audit trail of edits, approvals and access
  • Hours and overtime totals that reconcile to itemised pay slips
  • Per-employee retention rules that survive offboarding
  • Access logging over payroll-relevant fields

Canada

Federal privacy law with provincial variants, and employment-standards record rules that are provincial rather than national.

Working time & records

Canada Labour Code Part III and provincial employment standards

Hours worked, overtime and vacation records are prescribed per jurisdiction, with federally regulated employers on the Labour Code and everyone else on the provincial ESA.

Data protection

PIPEDA, with Quebec's Law 25 and the Alberta/BC PIPAs

Quebec's Law 25 adds transparency duties around automated decisions and stricter consent handling for employee data.

Retention

Employment records generally retained for 36 months after the work is performed.

  • Per-session start, stop, break and project records
  • Manager approval recorded against every session
  • Attendance register and timesheet exports (CSV/PDF)
  • Append-only audit trail of edits, approvals and access
  • Hours and overtime records per employee and pay period
  • Configurable retention covering the 36-month expectation
  • Consent and access records for privacy requests

Inside the EU, the detail is national

The Working Time Directive sets the floor; each Member State decides what the record has to look like and how long you keep it. The four markets we serve directly:

Spain

Registro de jornada — Real Decreto-ley 8/2019

Daily start and end times for every worker, kept four years and produced on request to the worker, their representatives and the Inspección de Trabajo.

Germany

Arbeitszeitgesetz and BAG, 13 September 2022 (1 ABR 22/21)

The Bundesarbeitsgericht read a duty to record working time into existing occupational-safety law, ahead of the ArbZG reform. Works councils typically negotiate what may be recorded — which is where surveillance-style tools stall.

France

Code du travail, art. L.3171-2 and following

Where staff do not all work the same schedule, the employer must record hours individually — the evidential burden in an hours dispute effectively sits with the employer.

Italy

D.Lgs. 66/2003

Weekly hour ceilings averaged over a reference period, daily rest and overtime limits, all of which need per-day hours to demonstrate.

Questions we get a lot

Which countries does Workclave support?

Workclave runs anywhere your team has a browser. Where we go further is record formats and retention: India, the EU/EEA, the UK, the US, Australia, the UAE, Singapore and Canada each have their obligations mapped to what the product outputs, and the site shows the regime that matches your location.

Is Workclave a compliance product?

No, and it is worth being precise. Workclave produces the evidence layer — who worked, when, on what, approved by whom, retained for how long. Classifying employees, setting overtime rates and filing returns stay with you and your advisers.

We operate in several countries at once. Does that work?

Yes. Shifts, breaks, holidays, leave types and retention windows are configured per workspace, so an entity in Dubai and one in Berlin can hold different rules while rolling up to the same reporting.

Why does avoiding surveillance help compliance rather than hurt it?

Working-time law asks how long someone worked. Screenshots, keystroke logs and location trails answer a different question and create personal data you then have to justify — under the GDPR, the DPDP Act, or Illinois' BIPA where biometric capture is involved. Collecting only session structure keeps the record complete and the exposure small.

Where is our data stored?

EU customers are served from Netherlands infrastructure. A DPA is available on paid plans, sub-processors are documented, and access to payroll-relevant fields is scoped by role and logged.

Not legal advice

This page summarises statutes that change, and applies differently by employee category, sector, collective agreement and state or province. It is background on what Workclave records, not advice on what your organisation owes. Confirm your obligations with a qualified adviser in each jurisdiction.

Operating across borders?

Tell us which entities and countries you run, and we will show the workspace, retention and export setup that covers all of them from one system.

Book a demoSecurity & data handling