GPS and worker monitoring, country by country
GPS and worker monitoring in Netherlands
what you need to stay compliant
Updated on 3 August 2026
Competent authority
Autoriteit Persoonsgegevens (AP)Verified on 15 June 2026
What you risk
EUR 725,000 (reduced to EUR 50,000 on objection)related case, not GPS
Updated on 3 August 2026
What you need
5For each obligation we tell you whether it applies in this country: Yes means required, It depends means only in certain cases, No means not required.
What you need
For each obligation we tell you whether it applies in this country: Yes means required, It depends means only in certain cases, No means not required.
Works council (OR) consent before installing the system (WOR art. 27)
It dependsonly in certain casesWhere a works council (ondernemingsraad, OR) exists, the employer needs its prior consent (instemmingsrecht) before introducing a system that processes staff data or monitors attendance, behaviour or performance (WOR art. 27, points k and l). If the OR does not consent, the employer cannot proceed. This applies where an OR exists: it is mandatory from 50 employees upwards.
Wet op de ondernemingsraden (WOR), art. 27 (diritto di consenso del consiglio aziendale)
Authorisation from a labour authority before installing
Nonot requiredThe Netherlands does not require prior authorisation from a labour authority. The gatekeepers are OR consent and the GDPR. The data protection authority (AP) must be consulted beforehand only in the case of art. 36 GDPR, that is, if the DPIA reveals a high risk that cannot be mitigated.
Prior information of workers (art. 13 GDPR)
YesrequiredWorkers must be informed in advance and fully about what is monitored and why.
Autoriteit Persoonsgegevens, condizioni per il controllo dei dipendenti
Valid legal basis (legitimate interest with balancing; employee consent is usually not valid) and ban on continuous tracking
YesrequiredFor the AP, monitoring must be necessary and proportionate; the basis is usually legitimate interest with a balancing test, not the employee's consent (because of the imbalance of power). GPS on company vehicles is allowed for work trips, but not to systematically track private or off-duty movements.
Autoriteit Persoonsgegevens, condizioni per il controllo dei dipendenti
Impact assessment (DPIA) for employee monitoring and location data
YesrequiredThe AP's DPIA list expressly cites GPS systems in employees' vehicles and the systematic monitoring of workers' activities, as well as the large-scale processing of location data: in these cases the DPIA is mandatory.
Autoriteit Persoonsgegevens, lista dei trattamenti che richiedono una DPIA
The procedure, step by step
If an OR exists, obtain its consent (instemmingsrecht) before activating the system (WOR art. 27).
Identify a valid legal basis under the GDPR: usually legitimate interest with a balancing test, not the employee's consent.
Carry out the impact assessment (DPIA): for GPS on employees' vehicles and for large-scale location data it is required.
Inform workers in advance and fully (art. 13 GDPR).
Configure the system with data minimisation: work trips only, no continuous tracking or tracking of private movements.
If the DPIA reveals a high risk that cannot be mitigated, consult the AP beforehand (art. 36 GDPR).
If you switch systems: when you change your monitoring system or software, update and re-issue the privacy notice, and check whether the national agreement or authorisation for remote monitoring needs renewing. The provider (data processor), the data collected and the methods often change: the one provided earlier is not enough.
Who to contact
Autoriteit Persoonsgegevens (AP)
https://www.autoriteitpersoonsgegevens.nl/
The Netherlands has a single national authority, the AP; there is no regional breakdown.
Verified on 15 June 2026
The template to download
Download the free GPS privacy notice template for Netherlands
Employee geolocation privacy notice template, compliant with GDPR Art. 13, including the countryโs legal basis and supervisory authority. Fill in the blank fields and have it checked by your advisor.
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Fine from the Autoriteit Persoonsgegevens against a company for processing employees' fingerprints for attendance recording: biometric data (art. 9 GDPR) processed without a valid basis, because the employees' consent is not regarded as freely given owing to the imbalance of power. It is not a GPS case but it is the Dutch landmark case on employee attendance monitoring. The initial EUR 725,000 fine was reduced to EUR 50,000 in November 2020, on objection, because of the company's limited financial capacity during the coronavirus crisis.
Cite this page
You're free to cite it, as long as you credit the source with a link to this page.
GPS and worker monitoring in Netherlands: what you need to stay compliant - GeoTapp. https://geotapp.com/en-au/resources/gps-workers-eu/netherlands/Source: <a href="https://geotapp.com/en-au/resources/gps-workers-eu/netherlands/?utm_source=citazione&utm_medium=referral&utm_campaign=risorse">GPS and worker monitoring in Netherlands: what you need to stay compliant - GeoTapp</a>ยฉ 2026 GeoTapp. Data compiled and verified by GeoTapp. For full republication of the dataset or commercial use, get in touch.
Sources
- Wet op de ondernemingsraden (WOR), art. 27 (diritto di consenso del consiglio aziendale)
- Autoriteit Persoonsgegevens, lista dei trattamenti che richiedono una DPIA
- Autoriteit Persoonsgegevens, condizioni per il controllo dei dipendenti
- Autoriteit Persoonsgegevens, sanzione per il trattamento delle impronte dei dipendenti
- Eurofound, monitoraggio dei lavoratori nei Paesi Bassi
- Regolamento UE 2016/679 (GDPR)
This is an informational resource, not legal advice. Before activating a monitoring system, have your situation checked by a professional.
Want a system that is already compliant?
GeoTapp records the location only at clock-in, not continuously, and generates the notice for workers to sign. Try it for free.