Navigating workers' data rights in the digital age : a historical, current, and future perspective on workers' data protection

Over recent decades, comprehensive data protection legislation has proliferated worldwide, with a majority of jurisdictions enacting robust statutory regimes. Despite this abundance of legal standards, persistent challenges remain regarding the efficacy of these laws in protecting individuals‒particularly workers‒within the increasingly digitalised workplace. Workers are especially susceptible to harm due to entrenched power asymmetries and heightened risks of data exploitation, yet many existing legal frameworks provide insufficient or inconsistent protection, and some jurisdictions explicitly exclude workers from coverage. This research critically examines the multidimensional risks associated with workplace digitalisation and systematically analyses regulatory challenges and protection gaps across diverse jurisdictions. By integrating historical analysis, current policy initiatives, and comparative cross-jurisdictional perspectives, the study identifies structural deficiencies in prevailing approaches. It concludes by proposing policy solutions to advance worker-centric data governance frameworks, tailored to address the distinctive challenges of contemporary labour relations and to ensure more equitable and effective protection for workers in the digital age.