GPS tracking under UK GDPR
What the ICO expects when you track your vans and drivers: telling staff, a lawful basis, a DPIA, tracking only at work and keeping locations no longer than you need.
When a customer rings to ask where their van is, you want to answer without phoning the driver. But a driver's location is their personal data, so tracking it is covered by UK GDPR. The ICO's guidance on monitoring workers (opens in a new tab) sets out what it expects. Where the ICO says "must", the law requires it.
Have a clear purpose and a lawful basis
Decide why you track, such as planning the day, telling customers when you'll arrive, or finding a stolen van, and write it down. You must identify a lawful basis (opens in a new tab) for it. Most firms rely on legitimate interests, which means weighing your interests against your drivers' and recording the outcome. Where the law requires a record, such as a tachograph, you can rely on legal obligation.
Tell your drivers first
You must tell workers about any monitoring, in a way that is easy to understand, before it starts, and tell them again when it changes. The ICO is clear that you must inform workers and passengers of any vehicle monitoring (opens in a new tab). Say what is tracked, when, why, who sees it and how long it is kept.
Do a DPIA
You must carry out a data protection impact assessment before processing likely to be high risk. The ICO lists "processing location data of employees" among its examples of tracking (opens in a new tab), so most firms that track drivers should do one. Use it to check whether a less intrusive way would meet your purpose, and record the answer.
Track only while they work
If drivers can use a work vehicle privately, the ICO says you will rarely be able to justify monitoring that private use. Track working time, not drivers' own time.
Keep only what you need
You must not collect more than your purpose needs, and must not keep it longer. Have a retention schedule and delete locations when it says. Drivers can ask for the data you hold about them, and you must give it to them unless an exemption applies.
Tracking in DoRoutes
DoRoutes is set up to make this easier to get right:
- Drivers' phones share their location only while they are clocked in.
- A van's tracker can be set to report only while someone on the van is clocked in, or in the van's working hours.
- You choose how long locations are kept, from 1 to 24 months, and older positions are deleted automatically.
See Live GPS and tracking in the user guide.