Geolocation for company vehicles: updates to the CNPD guidelines

10 May 2021


Dorothée David

The CNPD guidelines for geolocating company vehicles were updated on 15 April 2021.

The CNPD explains that the use of geolocation devices by employers raises a number of issues in terms of data protection, and could entail risks when it comes to employee privacy.

The CNPD guidelines are not exhaustive, but they do cover certain principles and obligations applicable to geolocating employees (links are to web pages in French):

  1. Principle of lawfulness of data processing - link
  2. Principle of purpose - link
  3. Principle of transparency - link
  4. Principle of necessity and proportionality (data minimisation) - link
  5. Article L. 261-1 of the Labour Code: specific legal provisions for data processing for the purposes of monitoring within the context of employment relationships - link
  6. Does a data protection impact assessment (“DPIA”) need to be carried out for setting up and using a geolocation device? - link
  7. Other obligations by virtue of GDPR - link

You can download the CNPD geolocation guidelines (in French) here.