This guide is for you if you are preparing a telematics deployment, if your IT or legal team has asked "and what about GDPR", or if your drivers have reacted and you are looking for something to stand on.
Chapter 1What telematics actually measures
Three sources, three kinds of data: the device fitted in the vehicle; the connected vehicle at its manufacturer, with no hardware; the driver’s mobile app, which locates the phone and therefore the person, including outside the vehicle — the most intrusive of the three, and the one most often forgotten as such.
A position attached to a vehicle assigned to an identified person is personal data about that person. It is not the ownership of the vehicle that counts, it is whether the driver can be identified.
Which data do you actually need for the use you have in mind? Many projects collect a continuous position when the objective is satisfied by far poorer data. This is not a legal precaution: it is the minimisation principle, and it is also what will get the project accepted internally.
Chapter 2Permitted purposes and forbidden uses
The six recognised purposes
- Tracking and invoicing a transport service for people or goods.
- Ensuring the safety of employees, goods or vehicles.
- Allocating resources better for work carried out in scattered locations.
- Tracking working time, as a secondary purpose only.
- Complying with a legal or regulatory obligation.
- Checking that the rules on vehicle use are followed.
The six forbidden uses
- Checking compliance with speed limits.
- Monitoring an employee permanently.
- Tracking an employee who is free to organise their own journeys.
- Tracking a staff representative in the exercise of their mandate.
- Collecting location outside working time, commutes and breaks included.
- Calculating working time when another system already does it.
The employee must be able to switch off the collection or transmission of their location outside working time. The employer can monitor how often this happens and act on abuse, but cannot remove the possibility. A system that does not provide for it is non-compliant, however good the rest of the project.
Chapter 3Choosing a legal basis and documenting it
The employer’s legitimate interest is the most common basis: it requires a real interest, processing that is necessary to achieve it, and no disproportionate impact on employees’ rights. That test is documented, not asserted. Consent is rarely relevant in an employment relationship: subordination makes it hard to consider freely given.
| Document | What it contains | Who asks for it |
|---|---|---|
| Record of processing | Purposes, data, recipients, periods, security | The authority in an inspection |
| Legitimate interest assessment | Interest, necessity, balancing | The authority, a court in a dispute |
| Impact assessment | Risks to people and the measures that reduce them | The authority, when the risk is high |
| Information notice | What is told to employees | Employees, works council, labour inspectorate |
These documents are not produced after the fact. Written at deployment they cost a few hours; written after a complaint they cost far more and come out worse.
Chapter 4Informing employees and consulting the works council
The information notice carries the identity of the controller, the purposes stated precisely — not "improving management" —, the legal basis, the recipients including providers, the retention period of each category, the rights of access, rectification and objection, and the possibility of lodging a complaint with the authority.
Consulting staff representatives comes before deployment. It is not an end-of-project formality: a system deployed before consultation can be challenged, and the discussion that should have happened upstream then happens downstream, in worse conditions.
Everything you do not say will be assumed. And what is assumed is always worse than the reality.
SourceCNIL — Example information notice for vehicle tracking (in French)
Chapter 5Retention periods and minimisation
| Use | Period |
|---|---|
| General rule | 2 months |
| Route optimisation, proof of work done | 1 year |
| Working time tracking | 5 years |
An automatic purge, not a manual one that gets forgotten: a period announced and not applied is worse than a long period owned up to. And different periods per category — raw positions are not kept as long as an aggregated report.
Three questions that shrink the footprint without shrinking the usefulness
- Do you need the position, or an event? "The vehicle arrived on site" is often enough, without keeping the journey.
- Do you need individual data, or an aggregate? A cost per kilometre per site does not need named journeys.
- Do you need continuous collection, or triggered collection? Event-based collection is less intrusive and often easier to explain.
SourceCNIL — Tracking of employees’ vehicles (check again at deployment, the doctrine evolves)
Chapter 6Security, processors and hosting
The company remains the controller; the vendor acts on its behalf, as a processor. The relationship is contractual: subject and duration of the processing, categories of data, security obligations, further processors, assistance with complaints or breaches, what happens to the data at the end of the contract.
The six questions to ask a vendor
- Where is the data hosted? The country, not the commercial region.
- Which further processors are involved? Host, router, the device’s mobile operator, support.
- Is there any transfer outside the European Union? And on what basis.
- How are accesses traced? Who sees what, and is it logged.
- What is the procedure in case of a breach? Deadline, contact, form.
- What happens at the end of the contract? Usable export, deletion deadline, proof of deletion.
These questions apply to any solution, ours included. A vendor that cannot answer them in writing leaves you carrying alone a risk that is in fact shared.
Chapter 7Deploying without turning the company against you
The real risk is not the fine: it is social. A badly prepared deployment produces conflict, systematic switching off, unplugged devices and unusable data. The company has paid for a system it cannot use.
The sequence that works
- Write the purposes first, on one page, before choosing a tool.
- Consult staff representatives with that document, not with a sales brochure.
- Inform each driver individually, explaining switching off outside working time and how it is done.
- Start with a narrow scope — one site, one category of vehicles — and learn from it.
- Show what it gives. A driver who sees that the data spared them a breakdown or defended a disputed invoice does not experience it the same way.
"Here is exactly what we collect, and what we do not." · "Here is how long it is kept, and what deletes it." · "Here is how you switch collection off outside work." None of them is a sales promise: they are verifiable facts, and that is why they work.
Go furtherGeofencing·The software evaluation grid·The fleet management guide
A demo is also the occasion to check in writing what this guide teaches you to ask.