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GDPR Data processing modelGeolocation and Monitoring of Employee-Assigned Vehicles

PrivateHuman resources
This processing concerns the geolocation and monitoring of vehicles assigned to employees for safety and security purposes, compliance with transport regulations, monitoring of working hours (when no alternative exists), and tracking or invoicing transport-related services.

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

1
Safety/security of employees and assets
Legitimate interest
Legitimate interests (Art. 6(1)(f) UK GDPR
2
Tracking/invoicing transport services
Track and invoice a transport service or one directly linked to vehicle use
Legitimate interest
Legitimate interests (Art. 6(1)(f); necessity for operational efficiency and billing accuracy).
3
Monitoring working time (where no other means are possible)
Track employee working time when this tracking is impossible by other means
Legitimate interest
(Art. 6(1)(f); ICO guidance on employee monitoring: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/employment/monitoring-workers/).
4
Compliance with specific transport obligations
Comply with an obligation imposing the implementation of such a device due to the type of transport nature of the goods
Legal obligation
Legal obligation (Art. 6(1)(c); e.g., Road Transport (Working Time) Regulations 2005).

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 access usedrequired

Data conservation rules

Active base:

Active use ≤ 3 months

proportionate under accountability principle; ICO employment data retention guidance.

Intermediate archiving:

For legal claims/security incidents: ≤ 6 months.

proportionate under accountability principle; ICO employment data retention guidance.

Destruction

Additional vehicle use data

Data details


Number of stopsrequired
Driving timerequired
Duration of vehicle userequired
Distancerequired
Speedrequired

Data conservation rules

Active base:

Active use ≤ 2 months. 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

Intermediate archiving:

Intermediate storage for service proof/disputes ≤ 1 year. Working time data (hours worked) may be retained up to 6 years for statutory records

Limitation Act 1980, HMRC requirements

Destruction

Employee identification data

Data details


Vehicle license plate numberrequired
Internal registration numberrequired
Professional contact detailsrequired
Name and surnamerequired

Data conservation rules

Active base:

Active use ≤ 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

Intermediate archiving:

Intermediate storage ≤ 1 year for disputes. Contact/ID data related to employment kept according to statutory employment record retention (up to 6 years post-employment)

Destruction

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

  • Employees

Created at:07/08/2023

Updated on:08/01/2025

License: © Creative commons :
Attribution / Pas d'utilisation commerciale
CC-BY-NC AttributionPas d'utilisation commerciale

Nb using:11


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