[{"data":1,"prerenderedAt":166},["ShallowReactive",2],{"\u002Fguides\u002Fgps-tracking-uk-gdpr":3},{"page":4,"pages":149},{"id":5,"title":6,"body":7,"description":139,"extension":140,"image":141,"meta":142,"navigation":143,"order":141,"path":144,"placeholder":145,"seo":146,"stem":147,"__hash__":148},"guides\u002Fguides\u002Fgps-tracking-uk-gdpr.md","GPS tracking under UK GDPR",{"type":8,"value":9,"toc":129},"minimark",[10,32,37,51,55,69,73,87,91,94,98,101,105,108,121],[11,12,13,14,31],"p",{},"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 ",[15,16,22,23],"a",{"href":17,"rel":18,"target":21},"https:\u002F\u002Fico.org.uk\u002Ffor-organisations\u002Fuk-gdpr-guidance-and-resources\u002Femployment\u002Fmonitoring-workers\u002F",[19,20],"noopener","noreferrer","_blank","monitoring workers",[24,25,26],"span",{},[24,27,30],{"className":28},[29],"sr-only"," (opens in a new tab)"," sets out what it expects. Where the ICO says \"must\", the law requires it.",[33,34,36],"h2",{"id":35},"have-a-clear-purpose-and-a-lawful-basis","Have a clear purpose and a lawful basis",[11,38,39,40,50],{},"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 ",[15,41,44,45],{"href":42,"rel":43,"target":21},"https:\u002F\u002Fico.org.uk\u002Ffor-organisations\u002Fuk-gdpr-guidance-and-resources\u002Femployment\u002Fmonitoring-workers\u002Fdata-protection-and-monitoring-workers\u002F",[19,20],"identify a lawful basis",[24,46,47],{},[24,48,30],{"className":49},[29]," 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.",[33,52,54],{"id":53},"tell-your-drivers-first","Tell your drivers first",[11,56,57,58,68],{},"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 ",[15,59,62,63],{"href":60,"rel":61,"target":21},"https:\u002F\u002Fico.org.uk\u002Ffor-organisations\u002Fuk-gdpr-guidance-and-resources\u002Femployment\u002Fmonitoring-workers\u002Fspecific-data-protection-considerations-for-different-ways-or-methods-of-monitoring-workers\u002F#specific6",[19,20],"vehicle monitoring",[24,64,65],{},[24,66,30],{"className":67},[29],". Say what is tracked, when, why, who sees it and how long it is kept.",[33,70,72],{"id":71},"do-a-dpia","Do a DPIA",[11,74,75,76,86],{},"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 ",[15,77,80,81],{"href":78,"rel":79,"target":21},"https:\u002F\u002Fico.org.uk\u002Ffor-organisations\u002Fuk-gdpr-guidance-and-resources\u002Faccountability-and-governance\u002Fdata-protection-impact-assessments-dpias\u002Fexamples-of-processing-likely-to-result-in-high-risk\u002F",[19,20],"examples of tracking",[24,82,83],{},[24,84,30],{"className":85},[29],", 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.",[33,88,90],{"id":89},"track-only-while-they-work","Track only while they work",[11,92,93],{},"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.",[33,95,97],{"id":96},"keep-only-what-you-need","Keep only what you need",[11,99,100],{},"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.",[33,102,104],{"id":103},"tracking-in-doroutes","Tracking in DoRoutes",[11,106,107],{},"DoRoutes is set up to make this easier to get right:",[109,110,111,115,118],"ul",{},[112,113,114],"li",{},"Drivers' phones share their location only while they are clocked in.",[112,116,117],{},"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.",[112,119,120],{},"You choose how long locations are kept, from 1 to 24 months, and older positions are deleted automatically.",[11,122,123,124,128],{},"See ",[15,125,127],{"href":126},"\u002Fguide\u002Flive-gps-and-tracking","Live GPS and tracking"," in the user guide.",{"title":130,"searchDepth":131,"depth":131,"links":132},"",2,[133,134,135,136,137,138],{"id":35,"depth":131,"text":36},{"id":53,"depth":131,"text":54},{"id":71,"depth":131,"text":72},{"id":89,"depth":131,"text":90},{"id":96,"depth":131,"text":97},{"id":103,"depth":131,"text":104},"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.","md",null,{},true,"\u002Fguides\u002Fgps-tracking-uk-gdpr",false,{"title":6,"description":139},"guides\u002Fgps-tracking-uk-gdpr","mbh5E-zYGJPdiu_EzpAhnw_iKSLb9qG09m00_Y217UM",[150,153,156,157,160,163],{"path":151,"title":152,"order":141},"\u002Fguides\u002Fdigital-waste-tracking","Digital waste tracking at the tip",{"path":154,"title":155,"order":141},"\u002Fguides\u002Fdrivers-hours","Drivers' hours for vans and lorries",{"path":144,"title":6,"order":141},{"path":158,"title":159,"order":141},"\u002Fguides\u002Fpricing-a-removal","Pricing a removal",{"path":161,"title":162,"order":141},"\u002Fguides\u002Fwaste-carrier-permits","Waste carrier registration is becoming a permit",{"path":164,"title":165,"order":141},"\u002Fguides\u002Fwaste-transfer-notes","Waste transfer notes for removals and clearance firms",1793711177548]