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Data Workers: Formal Notice Served to Teleperformance SE
The CGT-FAPT, the Data Labelers Association, and The Oversight Lab have served a formal notice (mise en demeure) upon TELEPERFORMANCE SE, the parent company of the TP Group, demanding a comprehensive revision of its vigilance plan to adequately prevent the occupational risks to which data workers within the group's value chains are exposed.
This constitutes the first formal notice of this nature in Europe directed at the parent company of a major actor in AI value chains.
« The question is no longer whether multinational corporations are aware of what transpires within their global operations, but whether they are prepared to be held accountable for it. » »
— Ephantus Kanyugi, Data Labelers Association
- Affaire｜Justice environnementale｜Justice sociale
- 9 September 2026
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Severe risks documented in Kenya
The formal notice is substantiated, inter alia, by investigations conducted among current and former employees of the TP Group in Nairobi, assigned to content moderation for a social media platform.
The testimonies and documentary evidence compiled reveal several critical risks:
- Migrant workers in situations of vulnerability
Multiple employees report having worked for months without a valid permit, their legal regularization being contingent upon the employer. Some also report that social security contributions were deducted but remitted belatedly or not at all. - Exposure to violent and traumatizing content
The interviewed moderators describe daily exposure to extremely violent material, resulting in enduring detriments to their mental health. Several also contest the accessibility and confidentiality of the psychological support provided. - Fear of reprisal and impediments to the assertion of rights
Certain workers consented to testify solely under the condition of anonymity, fearing adverse professional consequences. Several further express apprehension that contesting their working conditions or engaging in trade union activities could jeopardize their employment.
A vigilance plan deemed inadequate
In the assessment of the signatory organizations, the vigilance plan published by TELEPERFORMANCE SE in 2026 fails to sufficiently address the specific risks inherent to data work, notably within content annotation and moderation activities.
They formally demand the corporation to:
- enhance the identification and assessment of the risks to which data workers are exposed;
- guarantee more protective employment conditions, specifically for migrant workers, and strictly observe trade union freedoms;
- mitigate exposure to violent and traumatizing content and adapt the structural organization of work accordingly;
- ensure the provision of independent, specialized, and genuinely accessible psychological counseling; ;
- implement an accessible whistleblowing mechanism, enabling workers to report violations without fear of retaliation;
- audit the efficacy of the adopted measures and enforce their reinforcement where necessary.
Next steps?
TELEPERFORMANCE SE is granted a statutory period of three months to respond to the formal notice and ensure compliance with its legal obligations.
In the absence of a satisfactory response, the signatory organizations reserve the right to initiate legal proceedings before the Paris Judicial Court (Tribunal judiciaire de Paris).
The organizations instituting the action
The formal notice is brought forth by:
- CGT-FAPT
Trade union federation representing workers in the postal and telecommunications sectors. - Data Labelers Association – Kenya
Kenyan workers' organization striving for the recognition and defense of data workers' rights. - The Oversight Lab – Kenya
Nairobi-based organization leveraging research and strategic litigation to safeguard human rights within the technology sector.
This legal action falls within the scope of AI-WORLd, the action-research program conducted by Intérêt à Agir in partnership with DiPLab – Institut Polytechnique de Paris, with the support of the European AI & Society Fund (EAISF) and the Digital Freedom Fund (DFF).
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