France slashes Amazon's GDPR fine from €32M to €15M over warehouse monitoring

France's highest administrative court has cut Amazon's data protection penalty by more than half, reducing a €32 million fine to €15 million in a ruling issued December 23, 2025. The Council of State overturned key findings by France's data protection authority regarding warehouse employee monitoring systems, determining that certain real-time productivity tracking tools meet legal requirements under European privacy law.

The original sanction stemmed from inspections conducted by the Commission Nationale de l'Informatique et des Libertés (CNIL) in November 2019 at Amazon France Logistique's administrative offices and two warehouse facilities. Following those inspections and subsequent investigations, the CNIL's restricted panel imposed the €32 million administrative fine on December 27, 2023, for multiple violations of the General Data Protection Regulation (GDPR).

The Council of State's decision represents a significant partial victory for Amazon, which operates extensive logistics operations across France employing thousands of warehouse workers. The ruling clarifies boundaries around workplace monitoring under GDPR, particularly regarding legitimate business interests versus employee privacy rights.

Court validates specific monitoring tools

The Council of State reversed CNIL findings on three specific employee monitoring indicators that the data authority had deemed unlawful. These systems track various aspects of warehouse worker activity through handheld scanners used during product handling tasks.

The "stow machine gun" indicator monitors time intervals between barcode scans during item storage tasks. According to the court ruling, this system only activates when less than 1.25 seconds separates two consecutive scans of items being stored. The indicator's purpose centers on identifying potential handling and storage errors within warehouses rather than imposing speed requirements on workers.

"The purpose and effect of this indicator is to signal that two professional actions have taken place in a particularly short, possibly abnormal, interval of time, in order to identify any handling and storage errors within the warehouses and to be able to remedy them," according to the court decision.

The court determined this processing does not impose constraints on employees regarding task completion speed and therefore does not infringe on private life or working conditions rights. The system applies only to one of four "direct tasks" that warehouse employees perform—specifically the random task of organizing items within storage areas.

The "idle time" indicator records scanner inactivity periods exceeding ten consecutive minutes during direct tasks. The court found this monitoring proportionate because it only triggers after substantial inactivity periods, not for shorter or more frequent pauses. Critically, the system does not govern legally mandated break times provided to employees.

"The investigation shows that the inactivity time indicator is only issued and processed when the portable scanner used by an employee assigned to one of the four direct tasks is inactive for a period of more than ten consecutive minutes," the ruling states.

The third validated system, the "latency time" indicator, monitors scanner activity immediately before and after scheduled breaks. The court concluded this limited temporal scope does not excessively infringe on employee privacy rights or working condition protections.

Data retention practices remain problematic

While validating specific monitoring tools, the Council of State upheld CNIL's findings regarding Amazon's data retention practices. The court agreed that storing all quality and productivity indicators for 31 days constituted a violation of GDPR's data minimization principle.

Amazon failed to demonstrate why retaining each disputed indicator for the full 31-day period was necessary for legitimate business purposes including employee reassignment, advice, support, work planning, and performance evaluation. The GDPR requires data controllers to prove compliance with minimization requirements under Article 5(2).

"The applicant company does not establish the necessity, in view of the various purposes mentioned in the previous point, of retaining each of the disputed indicators for a long period of 31 days," the court determined.

The data minimization violation proved central to justifying the administrative fine, though at a reduced amount compared to CNIL's original penalty. The court characterized the breach as reflecting "serious negligence" given the large data volumes stored for an unjustified duration.

Privacy regulations have increasingly scrutinized employer monitoring practices, particularly as workplace surveillance technologies become more sophisticated. Amazon's case highlights ongoing tensions between operational efficiency goals and employee privacy protections.

Multiple technical violations confirmed

Beyond the monitoring and data retention issues, Amazon France Logistique did not contest several additional GDPR violations found by CNIL. These included failures to properly inform temporary workers about human resources privacy policies, inadequate information regarding video surveillance implementation in two warehouses, and insufficient security measures for video surveillance software access.

The court noted these uncontested violations contributed to the overall penalty calculation, though the primary basis for the fine centered on data minimization failures rather than the initially challenged monitoring systems.

The CNIL's restricted panel had originally determined the contested employee monitoring represented excessive infringement on workers' rights to private life and safe working conditions. The panel considered warehouse employees as vulnerable persons requiring heightened data protection, though the Council of State clarified this vulnerability assessment only applied to justifying public disclosure of the sanction rather than establishing the underlying violations.

Fine calculation methodology examined

The Council of State addressed Amazon's arguments about penalty proportionality and the CNIL's reasoning process. Under GDPR Article 83, administrative fines must be "effective, proportionate and dissuasive" with maximum penalties reaching €20 million or 4% of global annual turnover for violations of Articles 5 and 6.

The court rejected Amazon's claim that CNIL failed to adequately explain the fine amount calculation. French administrative law does not require data protection authorities to provide detailed figures showing how penalty amounts are determined, only that decisions must state legal and factual bases.

"There is no provision requiring the restricted panel of the CNIL to explain the amount of the sanctions it imposes," the ruling notes.

The court found Amazon could not have been unaware of the unlawful nature of its data retention practices given the excessive volumes stored over unjustified periods. This established the negligence required under GDPR Article 83(2)(b) for imposing financial penalties.

Technology companies face mounting regulatory scrutiny over data handling practices, with enforcement actions increasingly targeting workplace surveillance systems. The Amazon case demonstrates that while authorities maintain broad enforcement powers, courts will scrutinize specific technical implementations rather than categorically rejecting monitoring technologies.

Publication requirements persist

The Council of State maintained CNIL's requirement to publicly disclose the sanction, though with the reduced fine amount. The decision must be published on both the CNIL website and France's official legal publication platform Légifrance, following the same procedures as the original December 2023 deliberation.

Under the original CNIL decision, Amazon France Logistique would be identified by name in public disclosures for two years following publication before anonymization. The court's ruling did not modify this public disclosure timeline.

The court declined Amazon's request to refer questions to the Court of Justice of the European Union for preliminary rulings on GDPR interpretation, finding no reasonable doubt about applicable legal standards. This determination suggests French administrative courts view the relevant GDPR provisions as sufficiently clear for domestic application without EU-level guidance.

Amazon France Logistique must pay €3,000 to CNIL for legal costs, significantly less than the €10,000 Amazon requested from the data authority. The court dismissed remaining claims beyond the fine reduction and partial annulment of monitoring system violations.

Implications for workplace monitoring

The decision establishes important precedents for how French and potentially broader European authorities evaluate workplace monitoring systems under GDPR. The ruling suggests that monitoring tools serving clearly defined operational purposes—such as quality control or equipment management—may satisfy legitimate interest requirements when properly scoped.

Several factors proved decisive in validating Amazon's monitoring systems. The "stow machine gun" indicator only applies to specific warehouse tasks rather than continuous employee surveillance. The "idle time" indicator uses substantial time thresholds (ten minutes) rather than tracking minor activity fluctuations. The "latency time" indicator operates within narrowly defined temporal boundaries around scheduled breaks.

Conversely, the data retention violations stemmed from Amazon's inability to justify why comprehensive indicator storage for 31 days served articulated business purposes. Organizations implementing workplace monitoring must demonstrate not only legitimate business needs but also proportional data retention practices aligned with specific operational requirements.

European data protection authorities have accelerated GDPR enforcement since the regulation took effect in 2018, with workplace monitoring representing a growing enforcement priority. The Amazon case illustrates that while monitoring technologies face regulatory skepticism, technically sound implementations supporting demonstrable business needs may withstand legal challenges.

The €15 million final penalty, while reduced from the original amount, still represents a substantial financial consequence for data protection violations. This suggests that even when organizations successfully contest specific technical findings, courts will maintain significant penalties for confirmed violations like excessive data retention.

French labor organizations have consistently criticized Amazon's warehouse management practices, arguing that productivity monitoring systems create unhealthy working conditions. The court's partial validation of certain monitoring tools may intensify these debates while providing legal clarity about permissible workplace surveillance boundaries under current European law.

Timeline

• November 2019: CNIL conducts inspections at Amazon France Logistique administrative offices and two warehouses
• December 27, 2023: CNIL's restricted panel imposes €32 million administrative fine on Amazon France Logistique for multiple GDPR violations
• March 22, 2024: Amazon France Logistique files initial appeal with Council of State
• June 21, 2024: Amazon submits supplementary brief to Council of State
• March 12, 2025: Amazon files reply brief with Council of State
• December 12, 2025: Council of State holds deliberation session on Amazon's appeal
• December 23, 2025: Council of State issues ruling reducing fine to €15 million and overturning findings on three monitoring systems

Summary

Who: Amazon France Logistique, the French logistics subsidiary of Amazon, and the Commission Nationale de l'Informatique et des Libertés (CNIL), France's data protection authority

What: France's Council of State reduced Amazon's GDPR penalty from €32 million to €15 million, overturning violations related to three employee monitoring systems while upholding findings on excessive data retention practices

When: The Council of State issued its ruling on December 23, 2025, addressing a December 27, 2023 CNIL decision that followed November 2019 warehouse inspections

Where: The case involves Amazon France Logistique's warehouse operations across France, with the Council of State serving as France's highest administrative court reviewing CNIL enforcement actions

Why: The court found certain warehouse monitoring tools legally justified under GDPR's legitimate interest provisions while determining Amazon violated data minimization requirements by retaining productivity indicators for 31 days without adequate justification, reflecting broader tensions between operational efficiency and employee privacy rights in modern logistics operations