Article 29 Working Party Opinion 2/2017 on Data Processing at Work (WP249)
Sections 5.5 to 5.7: Time and attendance, video and vehicles – Article 29 Working Party Opinion 2/2017 on Data Processing at Work (WP249)

Article 29 Working Party Opinion 2/2017 on Data Processing at Work (WP249) 5.7(c): 5.7(c) No location monitoring outside agreed working hours, save a proportionate theft safeguard

Given how sensitive location data is, a lawful basis for following where employees' vehicles are beyond agreed working hours will rarely exist. If there is a real need, such as theft prevention, the implementation should be proportionate: no location registered outside hours unless the vehicle leaves a broadly defined region, and location revealed only on a break-glass basis when it does.

Maintained by Gerard Blokdyk

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  • GDPR-Art.5 Principles relating to processing of personal data

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Other controls in Sections 5.5 to 5.7: Time and attendance, video and vehicles – Article 29 Working Party Opinion 2/2017 on Data Processing at Work (WP249)

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