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Direito do Trabalho, Transformação Digital, Adequação da LGPD e Seus Aspectos Jurídicos.

* Denilson José da Silva Prestes– Advogado.

http://www.linkedin.com/in/denilson-prestes/

O presente artigo, tem o propósito de elencar através de uma breve análise, trazendo o Direito do Trabalho, discorrendo sobre a reforma trabalhista (Lei 13.467∕2017) que trouxe impactos nas relações entre empregado e empregador, por outro lado a pandemia acelerou a transformação digital, depreende-se que a mesma poderá criar impactos negativos (criando uma precarização das relações de trabalho) e de caráter positivo (criando novos postos de trabalho) diretamente aos empregados. E por fim, analisar se a adequação da LGPD com seus aspectos jurídicos, necessita por conseguinte da figura dos empregados-colaboradores juntamente com os empregadores e gestores, para uma profícua implementação da LGPD nas empresas, que lidam com utilização de dados pessoais dos titulares.

Primeiramente, quando se fala em Direito do Trabalho, não há como deixar de referir de que a reforma trabalhista através da sua Lei 13.467∕2017, trouxe consigo uma insegurança jurídica que impactou as relações entre empregado e empregador, no qual foi propagada a possível criação de um potencial de geração de empregos, mas que na prática ocorreu o contrário.

Além, de legalizar e institucionalizar as diversas modalidades “ditas” flexíveis de trabalho e emprego, referida Lei 13.467∕ 2017, a mesma dificulta o acesso dos trabalhadores à Justiça do Trabalho, bem como excluiu limites constitucionais e legais necessários para um trabalho decente e protetivo, extinguindo por conseguinte uma série de direitos dos trabalhadores.

Outrossim, em tempos de pandemia ocorreu uma aceleração no mercado, igualmente, um aumento em ascendência do desemprego, no qual milhões de pessoas ingressantes na força do trabalho se descobriram sem emprego. E aqui temos duas faces, a primeira impactada pela revolução tecnológica de forma negativa decorrente do alto índice de desemprego e por outro lado tivemos trabalhadores que foram favorecidos pela revolução tecnológica, de forma positiva, tendo seus postos de trabalho direcionados para o “tele trabalho”[1] e “home-office”[2], criando uma nova formatação laboral, que já possui regramento disciplinado na lei precitada 13.467∕ 2017.

Todavia, esta transformação tecnológica, trouxe uma nova realidade, no qual grande parte das empresas não estão devidamente preparadas. É sabido, que muitas das empresas, como referido anteriormente, não se prepararam ou não criaram condições ideais para seus colaboradores para atuarem em “teletrabalho” e “home office”, isto em termos trabalhistas e de segurança digital.

Igualmente, sob a ótica da cultura digital, esta aceleração referida anteriormente, criou um processo de transformação digital onde as empresas deverão utilizar a tecnologia para melhorar seu desempenho, ampliar seu alcance e otimizar os resultados em seu negócio empresarial. Como se observa o digital estava na “porta” da empresa tradicional e atualmente temos o digital no centro de tudo.

Para melhor compreensão do tema, não basta em tempos atuais (pandemia), transferir os empregados-colaboradores das empresas para suas residências como falávamos anteriormente, e não dispor de um treinamento efetivo, ou não propiciar efetivas condições dos mesmos, principalmente aqueles empregados-colaboradores que laboram em empresas que lidam com dados pessoais dos titulares.

Pois como afirma Frank Pasquale[3], os controladores de dados criaram um sistema desenhado não para tratar os titulares de dados decentemente, mas sim para maximizar seus lucros ou colocar a inovação acima de qualquer outro valor.

Neste novo cenário jurídico, surge a Lei Geral de Proteção de Dados (LGPD- Lei 13.709-2018) e diante das drásticas mudanças que a transformação tecnológica impôs, igualmente no cenário econômico, social e político, podemos afirmar que o objetivo precípuo da LGPD é resgatar a dignidade dos titulares de dados e seus direitos básicos relacionados a autodeterminação informativa.

Ademais, parte-se do pressuposto de que a LGPD criará uma necessária “interação com a autorregulação ou corregulação, com a própria tecnologia e com a autodeterminação informativa dos cidadãos potencialmente traduzida no consentimento”. [4]

Neste sentido, observa-se que a partir da implementação da Lei Geral de Proteção de Dados (LGPD) a mesma deverá funcionar como um processo de engrenagem, com o envolvimento dos seus empregados-colaboradores (desde que a empresa crie esta mentalidade e propicie reais condições laborais para os mesmos), que passe por um processo de engajamento (conexão multidisciplinar e seminários de motivação), passe por um diagnóstico (analisando os processos críticos e níveis de exposição), ocorra um planejamento efetivo (cuidado com os detalhes), execução (mudanças serão necessárias) e chegue a governança de dados como estratégia (busque apoio externo e capacitação de toda a organização).

Em conclusão, se faz imprescindível elencar na medida em que os avanços tecnológicos, e a ampliação dos mercados ocorrem, tendem a “despersonalizar” o trabalhador por aniquilar algumas conquistas sociais e fomentar o predomínio da perversa lógica econômica global. Por outro lado, decorrente da análise feita há que se ter um novo olhar para os empregados-colaboradores que se encontram no mercado de trabalho, e que foram direcionados para o “teletrabalho” e “home office”, para que os mesmos tenham uma qualidade digna de trabalho fazendo este link com o empregador (empresa).

Por sua vez, esta revolução e transformação digital que estamos vivenciando, trouxe inúmeras mudanças tecnológicas[5] por intermédio da conectividade digital, sobretudo em tecnologias de software que transformarão profundamente todas as relações humanas e as relações de trabalho.

Como visto, o surgimento de novas ocupações vinculadas as transformações tecnológicas, exige de um lado, profissionais altamente qualificados e, de outros, trabalhadores especializados, e por conseguinte aqueles empregados-colaboradores que laboram em empresas que lidam com dados pessoais dos titulares, devem ser orientados, valorizados, incentivados dentro desta nova ótica tecnológica.

Neste compasso, as empresas devem buscar um engajamento com seus colaboradores-trabalhadores, ou seja, a jornada LGPD se dará com a participação destes passando por um processo de médio a longo prazo, que passa por um diagnóstico, planejamento efetivo, execução até chegar a governança de dados como estratégia (buscando apoio externo e capacitação de toda a organização).

Portanto, é importante conhecer que A LGPD (13.709/18), antes de tudo, é uma regulação de riscos. Isso porque, além de garantir direitos e prescrever princípios, ela traz dispositivos voltados aos controladores de dados pessoais para que documentem suas atividades, prestem contas e também calibra sanções de acordo com o nível das medidas de prevenção ao risco adotadas previamente.

[1] A Lei nº 13.467/2017 (Reforma Trabalhista) trouxe normatização própria acerca do teletrabalho pela primeira vez, por meio dos artigos 75-A ao 75-E da CLT. Anteriormente, a CLT não fazia distinção do trabalho realizado no estabelecimento do trabalhador ou à distância. Neste sentido, de acordo com a CLT, o teletrabalho consiste na: “(…) prestação de serviços preponderantemente fora das dependências do empregador, com utilização de tecnologias de informação e comunicação que, por sua natureza, não se constituam como trabalho externo. (Incluído pela Lei nº 13.467, de 2017)” (CLT Art. 75-B) A prestação do serviço em caráter de teletrabalho pode se dar em qualquer lugar, sendo preponderantemente fornecido fora das dependências do empregador, podendo ser prestado da residência do empregado.

[2] Por sua vez, o home office se caracteriza quando o trabalho é realizado remotamente de maneira eventual na residência do empregado, podendo ou não configurar a hipótese de teletrabalho, sendo benéfico principalmente em casos de emergências como pandemias, enchentes e greves. Nem todas as atividades em home office se utilizam da tecnologia, que é condição preponderante para caracterização do teletrabalho. No home office pode existir uma flexibilização no regime de trabalho presencial, onde o empregado pode prestar o serviço alguns dias em sua residência remotamente. Não precisa constar em contrato individual de trabalho ou aditivo contratual, devendo ser regulado por política interna da empresa. Neste sentido, o home office poderá ser caracterizado como teletrabalho, quando utilizar tecnologias de informação e comunicação, não for eventual e não configurar qualquer hipótese de trabalho externo. (Grifei).

[3] PASQUALE, Frank. The black box society. The secret algorithms that control Money information. Cambridge։ Harvard University Press, 2015.p.146

[4] Lei Geral de Proteção de Dados Pessoais e suas repercussões no direito brasileiro- Ana Frazão, Gustavo Tepedino, Milena Donato Oliva coordenação- 1.ed. São Paulo։ Thomson Reuters Brasil, 2019, p.100.

[5] (…)anteriormente ao advento da revolução digital, muitas atividades eram inerentes tão somente aos humanos. Entrementes, hoje em dia os robôs e a s maquinas em geral assumiram tal posição, e há uma perspectiva de que em curto espaço de tempo consigam ofuscar o homem na realização de boa parte de suas atividades, inclusive laborais. (Direito do Trabalho e Novas Tecnologias, Werner Keller, São Paulo, Almedina, 2020, p.260).

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