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GeoTapp / Resources / United Kingdom

GPS and worker monitoring, country by country

GPS and worker monitoring in United Kingdom
what you need to stay compliant

Updated on 15 June 2026

Competent authority

ICO (Information Commissioner's Office)

Verified on 15 June 2026

What you risk

enforcement notice + warning (no fine); UK GDPR risk of up to 17.5 million pounds or 4% of turnover

related case, not GPS

Updated on 15 June 2026

What you need

5

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.

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.

  • Consultation of workers or their representatives before introducing monitoring

    It dependsonly in certain cases

    The ICO asks employers to gather and document the views of workers or their representatives (e.g. trade unions) before introducing monitoring, unless there are good reasons not to; it is not binding consent, but it must be documented.

    ICO, guida sul monitoraggio dei lavoratori (UK GDPR)

  • Prior authorisation from an authority before installation

    Nonot required

    No prior authorisation from the ICO is required; accountability applies (self-assessment + DPIA). The ICO must be consulted in advance only if the DPIA identifies a high risk that cannot be mitigated.

    ICO, guida sul monitoraggio dei lavoratori (UK GDPR)

  • Valid legal basis and information to workers (usually legitimate interests, not consent; no covert surveillance)

    Yesrequired

    Consent is usually not valid because of the imbalance of power; the usual basis is legitimate interests with a documented assessment (LIA). Workers must be informed clearly; covert surveillance is allowed only in exceptional cases.

    ICO, guida sul monitoraggio dei lavoratori (UK GDPR)

  • No unjustified continuous tracking; deactivation outside working hours for private use

    Yesrequired

    According to the ICO, continuous recording while the vehicle is used for private purposes outside working hours is likely to be excessive; the driver must be able to switch off the recording in those cases.

    ICO, sorveglianza nei veicoli

  • Data protection impact assessment (DPIA) for tracking workers' geolocation

    Yesrequired

    The ICO's list expressly includes tracking a person's geolocation or behaviour; for GPS on employees a DPIA is required.

    ICO, quando serve una DPIA

The procedure, step by step

  1. Gather and document the views of workers or their representatives.

  2. Identify a valid legal basis (usually legitimate interests) and carry out the documented assessment (LIA).

  3. Carry out the data protection impact assessment (DPIA) before activating the tracking.

  4. Inform workers in a clear and accessible way (no covert surveillance except in exceptional cases).

  5. Configure the system: no continuous recording outside working hours, deactivation for private use.

  6. 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.

PROVA GPSREPORT SIGILLATOVERIFICA INDIPENDENTENESSUNA SORVEGLIANZADATI IN EUROPAFUNZIONA OFFLINEPROVA GPSREPORT SIGILLATOVERIFICA INDIPENDENTENESSUNA SORVEGLIANZADATI IN EUROPAFUNZIONA OFFLINE

Who to contact

The template to download

Download the free GPS privacy notice template for United Kingdom

Employee geolocation privacy notice template, compliant with GDPR Art. 13, including the countryโ€™s legal basis and supervisory authority. Fill in the blank fields and have it checked by your advisor.

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What you risk: enforcement notice + warning (no fine); UK GDPR risk of up to 17.5 million pounds or 4% of turnover

ICO against the Home Office (1 March 2024): enforcement notice and warning for failing to adequately assess the intrusiveness of continuous GPS tracking (ankle tag on people under immigration powers), inadequate DPIA, no evidence of necessity and proportionality. It is not an employee case, but the ICO's reasoning on continuous GPS tracking is directly transferable.

https://ico.org.uk/about-the-ico/media-centre/news-and-blogs/2024/03/ico-finds-the-home-office-s-pilot-of-gps-electronic-monitoring-of-migrants-breached-uk-data-protection-law/

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GPS and worker monitoring in United Kingdom: what you need to stay compliant - GeoTapp. https://geotapp.com/en-au/resources/gps-workers-eu/united-kingdom/
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ยฉ 2026 GeoTapp. Data compiled and verified by GeoTapp. For full republication of the dataset or commercial use, get in touch.

Sources

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.