Concrete things that are highlighted as out-of-bounds:
1) Putting a dummy security camera in a breakroom
2) Hiring someone to sit in a car in the company parking lot and pretend to talk into a phone every time someone goes to their car
Given that wide constraint, I can definitely see how "hiring an intelligence analyst who would specifically be tasked with keeping the company high-level leadership informed about labor threats to the company" could be interpreted, reasonable-person-wise, as the company surveilling organized labor. I don't think it's the slam-dunk some are describing it as, but it's, if you will, "a bad look."