GPS and worker monitoring, country by country
GPS and worker monitoring in Luxembourg
what you need to stay compliant
Updated on June 15, 2026
Competent authority
CNPD (Commission nationale pour la protection des donnees)Verified on June 15, 2026
What you risk
2,800 €from a real GPS case
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 collective information to the staff delegation and codecision (Code du travail art. L.261-1)
It dependsonly in certain casesBefore installing monitoring, the employer must inform the staff delegation in advance; for the purposes provided for, deployment is subject to codecision with the delegation. This applies where a staff delegation exists.
Code du travail, art. L.261-1 (sorveglianza dei lavoratori) - riproduzione CNPD
Possibility for the delegation or the workers to request a prior opinion from the CNPD within 15 days (suspensive effect)
It dependsonly in certain casesThe staff delegation, or in its absence the workers concerned, may request an opinion from the CNPD within 15 days of the prior information, and the request has suspensive effect.
Code du travail, art. L.261-1 (sorveglianza dei lavoratori) - riproduzione CNPD
Prior authorisation from an authority before installing
Nonot requiredThe old prior authorisation from the CNPD was abolished with the GDPR and replaced by codecision with the staff delegation; the obligation to keep the record of processing activities remains.
CNPD, geolocalizzazione dei veicoli: necessità e proporzionalità
Basis = a condition of GDPR art. 6 and individual information; no permanent tracking if private use is allowed, deactivatable by the worker
YesrequiredA basis under GDPR art. 6 and individual information (art. 13) are required; the employer cannot monitor outside working hours, and if private use of the vehicle is allowed the system cannot remain permanent and the worker must be able to deactivate it.
CNPD, geolocalizzazione dei veicoli: necessità e proporzionalità
Impact assessment (DPIA) for geolocation that regularly or systematically monitors employees (e.g. for working time)
YesrequiredAn impact assessment is required when geolocation involves regular and systematic monitoring of employees or tracks their working time.
The procedure, step by step
Inform the staff delegation in advance and activate codecision (art. L.261-1).
Allow the delegation or the workers the possibility to request an opinion from the CNPD within 15 days (suspensive effect).
Identify a legal basis under GDPR art. 6 and inform the workers individually (art. 13).
Carry out the impact assessment (DPIA) if the geolocation regularly monitors employees.
Configure the system: no permanent tracking if private use is allowed, deactivatable by the worker.
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
CNPD (Commission nationale pour la protection des donnees)
https://cnpd.public.lu/fr/support/protection-des-donnees.html
https://cnpd.public.lu/fr/support/protection-des-donnees.html
Luxembourg has a single national authority, the CNPD; no regional division.
Verified on June 15, 2026
CNPD, reclami
https://cnpd.public.lu/fr/support/protection-des-donnees.html
https://cnpd.public.lu/fr/support/protection-des-donnees.html
Verified on June 15, 2026
The template to download
Download the free GPS privacy notice template for Luxembourg
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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CNPD, decision 11FR/2021 of 8 April 2021: a penalty against a company for a service-vehicle geolocation system operated unlawfully, with excessive data retention (2 years and 4 months), inadequate information to workers (art. 13) and insufficient security (art. 32). Fine of 2,800 euros.
https://cnpd.public.lu/fr/decisions-sanctions/2021/decision-11-fr-2021.html
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 Luxembourg: what you need to stay compliant - GeoTapp. https://geotapp.com/en/resources/gps-workers-eu/luxembourg/Source: <a href="https://geotapp.com/en/resources/gps-workers-eu/luxembourg/?utm_source=citazione&utm_medium=referral&utm_campaign=risorse">GPS and worker monitoring in Luxembourg: 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
- Code du travail, art. L.261-1 (sorveglianza dei lavoratori) - riproduzione CNPD
- CNPD, geolocalizzazione dei veicoli: necessità e proporzionalità
- CNPD, geolocalizzazione: valutazione d'impatto (AIPD)
- CNPD, decisione 11FR/2021 (sanzione geolocalizzazione veicoli di servizio)
- CNPD, presentare un reclamo
- 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.