GPS and worker monitoring, country by country
GPS and worker monitoring in Bulgaria
what you need to stay compliant
Updated on June 15, 2026
Competent authority
CPDP (Komisia za zashtita na lichnite danni)Verified on June 15, 2026
What you risk
up to 20 million euros or 4% of turnover (GDPR)statutory maximum, not a fine issued
Updated on June 15, 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.
Internal rules and worker information on systems for access, time and discipline control (ZZLD art. 25zh)
YesrequiredThe employer must adopt internal rules and procedures when introducing systems for controlling access, working time and labour discipline, setting out their scope, obligations and methods, and bring them to the workers attention.
Special rules for large-scale systematic monitoring, including video surveillance (art. 25i)
It dependsonly in certain casesFor large-scale systematic monitoring of publicly accessible areas, including video surveillance, special rules are required on legal bases, purposes, scope, retention and information.
Prior authorisation from an authority before installing
Nonot requiredNo prior authorisation from the CPDP is required; the controller adopts the internal rules itself and carries out the DPIA when required.
CPDP, lista dei trattamenti che richiedono una DPIA (art. 35.4)
Basis = legitimate interest (not consent, due to the imbalance of power); proportionality; no tracking during private use of the vehicle
YesrequiredAccording to the CPDP, consent can hardly be free in the employment relationship; the basis is legitimate interest, the processing must be proportionate and the employer cannot use tracking devices during private use of the vehicle.
CPDP (Garante bulgaro), guida sulla privacy sul luogo di lavoro (GPS)
Impact assessment (DPIA) for processing location data with profiling or for systematic monitoring
YesrequiredThe CPDP list includes processing of location data for profiling with significant effects; systematic monitoring of employees falls among the high-risk cases that require an impact assessment.
CPDP, lista dei trattamenti che richiedono una DPIA (art. 35.4)
The procedure, step by step
Adopt internal rules on the control systems and bring them to the workers attention (art. 25zh).
Identify a valid legal basis (legitimate interest, not consent) and document the proportionality.
Carry out the impact assessment (DPIA) for systematic monitoring or location data.
Inform the workers before activation (art. 13 GDPR).
Configure the system: no tracking during private use of the vehicle, only for the stated purposes.
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
CPDP (Komisia za zashtita na lichnite danni)
Bulgaria has a single national authority, the CPDP; there is no regional breakdown.
Verified on June 15, 2026
The template to download
Download the free GPS privacy notice template for Bulgaria
Employee geolocation privacy notice template, compliant with GDPR Art. 13, including the country’s legal basis and supervisory authority. Fill in the blank fields and have it checked by your advisor.
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There is no specific, published CPDP fine for GPS on employees. In an opinion of 24 November 2023, the CPDP held that the reuse of video surveillance recordings to assess the performance of LUKOIL Bulgaria employees was inadmissible (incompatible reuse, art. 6 para. 4 GDPR), without a fine. The sanction risk remains the general one under the GDPR (art. 83).
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 Bulgaria: what you need to stay compliant - GeoTapp. https://geotapp.com/en-ca/resources/gps-workers-eu/bulgaria/Source: <a href="https://geotapp.com/en-ca/resources/gps-workers-eu/bulgaria/?utm_source=citazione&utm_medium=referral&utm_campaign=risorse">GPS and worker monitoring in Bulgaria: what you need to stay compliant - GeoTapp</a>© 2026 GeoTapp. Data compiled and verified by GeoTapp. For full republication of the dataset or commercial use, get in touch.
Sources
- Legge sulla protezione dei dati (ZZLD), art. 25ж e 25и (controllo sul lavoro e monitoraggio su larga scala)
- CPDP (Garante bulgaro), guida sulla privacy sul luogo di lavoro (GPS)
- CPDP, lista dei trattamenti che richiedono una DPIA (art. 35.4)
- CPDP, parere su LUKOIL (riuso della videosorveglianza per valutare i dipendenti)
- CPDP (Garante bulgaro), pagina ufficiale
- 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.