Tracking employees and GDPR


You are entitled as an employer to use tracking devices in company vehicles.

Author: Polly Davies
Reading time: 2 minutes

This article is 3 years old.

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A long serving employee has recently complained about the tracker on his company vehicle in light of the GDPR.  Has the GDPR had any impact on the use of trackers in company vehicles?

The information from a vehicle tracking device is personal data as defined by the General Data Protection Regulation (GDPR) meaning any information relating to an identifiable person who can be directly or indirectly identified.  Location data is included in the definition.  This means that although there is a legitimate interest in collecting the data its use is strictly confined to stated organisational purposes only and, a clear workplace vehicle tracking policy is essential. 

Company vehicles are usually fitted with tracking devices using GPS for insurance purposes.  It can be an absolute requirement for insurance or it can bring down insurance costs.  However, tracker devices offer other benefits to companies in terms of operational efficiencies and safety and security benefits. 

You are entitled as an employer to use tracking devices in company vehicles, but it is a good idea to have a clear workplace policy setting out the details of the nature and extent of monitoring and each employee should consent in writing to the presence of the device.  The policy should clarify what private use can be made of vehicles provided by, or on behalf of, the employer, and any conditions attached to use.  The trackers should have privacy buttons. 

It is important that workers using the vehicles are aware of the policy.  It should be completely transparent, and all employees should be aware of the presence of tracking devices in the vehicles the use.  The purpose of the devices should be clearly explained and the rules on their use including what data the system can provide and how the data gathered will be used by managers, supervisors, the Transport Unit, and even clients and the general public if the case. 

Polly Davies

Legal Advisor

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