GDPR Data processing modelGeolocation of vehicles used by employees

By: Ludwig Karneth

Human resourcesPrivate

This processing model relates to ensuring the safety or security of the employee himself or of the goods or vehicles for which he is responsible, tracking the employee's working time, tracking and invoicing a transport service or related to the use of the vehicle as well as compliance with the obligation imposing the implementation of such a device due to the type of transport and nature of the goods.

Purposes (4)

A purpose is the objective pursued by the setting up of your file. It indicates what the processing of personal data will be used for, its purpose. This purpose must be clear and understandable

To ensure the safety or security of the employee himself or of the goods or vehicles in his charge

Legitimate interest

Track employee working time

When this tracking is impossible by other means

Legitimate interest

Comply with an obligation imposing the implementation of such a device due to the type of transport nature of the goods

Legal commitment

Track and invoice a transport service or one directly linked to vehicle use

Legitimate interest

Data categories (3)

Personal data is any information relating to an identified or identifiable natural person. A natural person can be identified either directly (eg surname and first name) or indirectly (eg phone number, social security number, email or postal address, but also voice or image)

Employee travel data

Data details

parking space numberoptional

Vehicle license plate numberoptional

Date and time of entry and exitrequired

Authorized access zones and timesrequired

Door number usedrequired

Data conservation rules

Active base:

Items relating to people's movements must not be kept for more than 3 months

Additional data associated with vehicle use

Data details

Number of stopsrequired

Driving timerequired

Duration of vehicle userequired

Number of kilometers traveledrequired

Traffic speedrequired

Data conservation rules

Active base:

Normally 2 months. They may be kept for longer than two months : - if a specific regulation so provides - if such conservation is made necessary for purposes of proof of the performance of a service, when it is not possible to provide such proof by any other means. In this case, the retention period is set at one year, which does not preclude a longer retention period in the event of a dispute over the services provided - if the retention is carried out to keep a record of journeys for the purpose of optimizing tours, for a maximum period of one year. As part of the monitoring of working hours, only data relating to hours worked may be kept for a period of five years

Employee identification

Data details

Vehicle license plate numberrequired

Internal registration numberrequired

Professional contact detailsrequired

Name and surnamerequired

Data conservation rules

Active base:

Data subject (1)

A data subject is any person whose data is collected, retained or processed by the data processing. e.g. In a recruitement process, any candidate for a position proposed in recruitement management process