PERB: OPERATION, JURISDICTION, AUTHORITY; APPLICABILITY OF AND CONFLICTS WITH OTHER STATUTES – NLRA/LMRDA Precedent

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CLARIFIED ON OTHER GROUNDS BY Trustees of the California State University v. Public Employment Relations Bd. (2026) 118 Cal.App.5th 90 and Trustees of the California State University (2026) PERB Decision No. 2915a-H.

The ALJ relied properly on NLRB authority finding negotiable an employer’s use of surveillance cameras in the work place. (Colgate-Palmolive Co. (1997) 323 NLRB 515.) The District distinguishes this NLRB decision on the ground that the surveillance cameras in question were hidden and that the premises in question were private. Such distinctions (overt vs. covert cameras, and public vs. private premises) are of no moment when assessing whether workplace surveillance of employees presents issues appropriate for meeting and negotiating the effects of an employer’s decision to install security cameras.