Geolocation of employees: what rules to respect?

Картинки по запросу "Geolocation of employees:"

Geolocation of employees: what rules to respect?

The geolocation of employees is a good example of the trivialization of new technologies within the company: it is a process allowing to determine the geographical position of an individual or an object at a specific time. This system has been subject to strict regulation by CNIL.


The first condition is essential: the employer can install a geolocation device only for a certain specific purpose. Thus, it is only possible for the employer to install such a system in the following cases:

  • Monitor, justify and invoice a passenger transport service;
  • Ensure the safety of the employee, goods or vehicles for which the employee is responsible;
  • Better allocate resources for services to be performed in dispersed places;
  • Track an employee’s working time, but only if this is not possible by any other means, even less efficient;
  • Comply with a legal or regulatory obligation to use geolocation;
  • Check compliance with the rules for using a vehicle provided by the employer.

The employer must also respect a principle of proportionality, fundamental in labor law. Thus, the employer must install a system proportional to the desired goal. For example, the employee must be able to deactivate the geolocation device himself. The employer must also respect a limited retention period for location data (two months are recommended by the CNIL).

Картинки по запросу "Geolocation of employees:"


The employer must also comply with formal conditions before setting up an employee geolocation system: he must first inform the employee representative bodies of his plan to introduce a geolocation system.

He must then inform the employee himself of the purpose of the device and his rights; this information must be personal and individual and can, for example, pass through an amendment to the employment contract.

Finally, the employer must make a declaration to the CNIL the installation of a geolocation system, because location data constitutes personal data; except, any processing of personal data requires a declaration to the CNIL.

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