GPS and worker monitoring, country by country
GPS and worker monitoring in Montenegro
what you need to stay compliant
Updated on June 15, 2026
Competent authority
AZLP (Agency for Personal Data Protection and Free Access to Information)Verified on June 15, 2026
What you risk
up to 20 million euros or 4% of turnover (general risk)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.
Prior written information to workers and internal GPS rules (ZZPL art. 20; AZLP position)
YesrequiredThe employer must inform workers about the purposes, methods, data collected and rights, and adopt internal rules on GPS processing together with a preliminary assessment of the security measures.
AZLP, posizione del Consiglio sull'uso del GPS nei veicoli di servizio (29.04.2025)
Prior authorisation from the supervisory authority before setting up the data filing system (ZZPL art. 27)
YesrequiredUnlike the GDPR, Montenegro retains an ex ante authorisation: before setting up a data filing system the controller must obtain the consent of the supervisory authority (if it does not reply within 30 days, consent is deemed granted).
Legge sulla protezione dei dati (ZZPL), testo ufficiale inglese
Basis = legitimate interest (art. 10), not consent; for private vehicles written consent and working hours only
YesrequiredThe basis is legitimate interest; for private vehicles used for work purposes the worker's written consent is required and the GPS must be limited to working hours.
AZLP, posizione del Consiglio sull'uso del GPS nei veicoli di servizio (29.04.2025)
No decisions about employees based solely on automated processing (ZZPL art. 15a)
YesrequiredDecisions about employees' performance, reliability or conduct cannot be based solely on automated processing; the worker must be able to express their own position.
AZLP, posizione del Consiglio sull'uso del GPS nei veicoli di servizio (29.04.2025)
Formal data protection impact assessment (DPIA)
It dependsonly in certain casesThe current law does not provide for a formal GDPR-style DPIA; the substitute is the prior authorisation under art. 27 plus the security measures and the preliminary adequacy assessment (arts. 24 and 26).
Legge sulla protezione dei dati (ZZPL), testo ufficiale inglese
The procedure, step by step
Define the purposes and methods of the GPS and adopt internal rules with a preliminary assessment of the security measures.
Obtain the prior authorisation of the supervisory authority before setting up the data filing system (art. 27).
Inform workers in writing; for private vehicles collect written consent and limit the GPS to working hours.
Do not base decisions about employees solely on automated processing (art. 15a).
Limit the GPS to working hours and to the declared purpose.
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
AZLP (Agency for Personal Data Protection and Free Access to Information)
https://www.azlp.me/en/contact
Montenegro is a candidate country, outside the EU, with a law only partially aligned with the GDPR. There is a single national authority, the AZLP. Distinctive feature: prior authorisation from the authority is required before setting up the data filing system (art. 27).
Verified on June 15, 2026
AZLP, tutela dei diritti
Verified on June 15, 2026
The template to download
Download the free GPS privacy notice template for Montenegro
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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There is no specific, published AZLP fine for GPS tracking of employees. The reference position is that of the AZLP Council of 2025: GPS on service vehicles is legitimate monitoring, but its purposes and methods must be defined, workers must be informed, internal rules must be adopted and the prior authorisation of the authority for the data filing system must be obtained.
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 Montenegro: what you need to stay compliant - GeoTapp. https://geotapp.com/en-us/resources/gps-workers-eu/montenegro/Source: <a href="https://geotapp.com/en-us/resources/gps-workers-eu/montenegro/?utm_source=citazione&utm_medium=referral&utm_campaign=risorse">GPS and worker monitoring in Montenegro: 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
- Legge sulla protezione dei dati (ZZPL), testo ufficiale inglese
- AZLP, posizione del Consiglio sull'uso del GPS nei veicoli di servizio (29.04.2025)
- AZLP (Garante montenegrino), contatti
- AZLP, moduli (richiesta di tutela dei diritti)
- Regolamento UE 2016/679 (GDPR), riferimento comparativo
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.