Algorithmic Exclusion of Informal and Migrant Construction Workers from Occupational Safety Governance in Türkiye
This paper critiques the assumption that digitalization inherently improves occupational safety governance by introducing the "Digital Shadow Labor" framework, which demonstrates how Türkiye's algorithmic OHS system systematically excludes informal and migrant construction workers through four filtering gates, thereby transforming their invisibility into a constitutive feature of governance rather than a temporary deficit.
Original paper licensed under CC BY 4.0 (https://creativecommons.org/licenses/by/4.0/). This is an AI-generated explanation of the paper below. It is not written or endorsed by the authors. For technical accuracy, refer to the original paper. Read full disclaimer
In the modern world, governments increasingly rely on digital systems to manage complex tasks, from distributing social benefits to ensuring that workplaces are safe. These systems operate on a simple premise: if a person is recorded in the database, they are seen by the state, and if they are seen, they are protected. This approach assumes that computerization solves old problems like missed inspections or lost paperwork by creating a clear, automated record of every worker and every employer. However, this logic contains a hidden flaw. If a worker is never entered into the system in the first place, the digital safety net does not just fail to catch them; it renders them completely invisible. When a government cannot see a worker, it cannot enforce the laws designed to keep that worker alive. This creates a paradox where the very tools meant to improve safety might accidentally make the most dangerous jobs even more dangerous by ignoring the people who need protection the most.
A researcher named Kaan Koçali from Istanbul Gelişim University has examined this exact problem in the construction industry of Türkiye. The country has built a highly advanced digital system called İSG-KATİP, which is integrated into the national e-government portal. This platform automatically registers workplaces, tracks whether safety experts are hired, and issues penalties if rules are broken. It is a model of efficiency for the workers it can see. Yet, Türkiye's construction sector is also home to a massive number of informal workers and migrants from Syria who often lack the official documents or the administrative support to get registered. Koçali's research asks a critical question: what happens to the safety of these unregistered workers when the entire system is designed to only protect those who are already on the list?
To answer this, the study introduces a new way of thinking called the "Digital Shadow Labor" framework. Instead of viewing digital exclusion as a single barrier, the researcher describes it as a series of four gates that a worker must pass through to be seen and protected. The first gate is identity. To enter the system, a worker needs a valid national identity card and a legal work permit. Many Syrian migrants and some local workers do not have these documents, so they are stopped immediately. They are not just underserved; they are effectively erased from the system before any safety rules can even apply to them.
The second gate is navigation. Even if a worker has the right papers, the system requires a certain level of administrative skill to use. In the construction industry, work is often organized through small subcontractors who may not have office staff or the technical know-how to register their employees correctly. A company might have all the legal documents but fail to enter the data into the digital portal because they do not know how. This creates a second layer of invisibility where workers are technically eligible for protection but are lost due to the complexity of the system.
The third gate is data visibility. Because the system only records the workers who pass the first two gates, the official statistics on workplace safety only reflect that specific group. Recent data from Türkiye shows that the construction industry accounts for a disproportionately high number of recorded deaths compared to its share of registered employment. However, the study points out that these numbers likely tell only part of the story. Since the unregistered workers are not in the database, their accidents and deaths are not counted in the official tallies. The data becomes "selectively blind," showing a picture of safety that is incomplete and potentially misleading.
The final gate is accountability. In a digital system, penalties are triggered automatically when a registered employer fails to meet safety requirements. But if a worker is not registered, the system has no way to know they exist. There is no automated alarm to sound when an unregistered worker is in danger, and no penalty is issued to an employer for hiring them. The system is highly accountable for the people it knows, but it has no mechanism to hold anyone responsible for the people it cannot see. This turns a temporary gap in the system into a permanent feature of how safety is governed.
The research suggests that this digital exclusion is not just a technical glitch but a structural issue that changes the nature of safety governance. In the past, a human inspector walking a construction site might use their judgment to notice an unregistered worker and take action, even if that worker was not on a list. A digital system, by contrast, follows strict logic that only recognizes what is entered into it. The study argues that without a specific design to include these invisible populations, digitalization risks making the problem of informality worse by hiding it. The unregistered workers remain physically present on the construction sites, facing the same risks of falling or injury as everyone else, but they are now invisible to the laws meant to save them.
The paper does not claim that digitalization is the cause of informal work or migration; those issues existed long before computers were used. Instead, it argues that by automating safety checks without a plan for the unregistered, the system creates a new kind of blindness. The official statistics, which show a high rate of deaths in construction, are likely an undercount because they miss the very people who are most at risk. The study concludes that for digital governance to be truly effective, it must acknowledge its own limits. This means creating ways for inspectors to flag unregistered workers, assessing how algorithms might exclude people before they are deployed, and finding legal pathways for informal workers to enter the system. Until these steps are taken, the digital safety net will remain a net that only catches those who are already visible, leaving the most vulnerable to fall through the cracks.
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