GPS and worker monitoring, country by country
GPS and worker monitoring in Portugal
what you need to stay compliant
Updated on August 3, 2026
Competent authority
CNPD (Comissao Nacional de Protecao de Dados)Verified on June 15, 2026
What you risk
up to 20 million euro or 4% of total annual worldwide turnoverstatutory maximum, not a fine issued
Updated on August 3, 2026
What you need
6For 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.
Informing workers of the existence and purpose of the surveillance (art. 20 Codigo do Trabalho)
YesrequiredThe employer must inform workers of the existence and purpose of the surveillance measures used.
Codigo do Trabalho, art. 20 (mezzi di sorveglianza a distanza)
Prohibition on using remote surveillance to monitor the worker's performance (art. 20 CT)
YesrequiredRemote surveillance may not be used to monitor professional performance; it is allowed only for the protection and safety of people and property or for particular needs of the activity.
Codigo do Trabalho, art. 20 (mezzi di sorveglianza a distanza)
Prior authorisation from an authority before installation
Nonot requiredWith the GDPR the old prior authorisation by the CNPD has fallen away; an a posteriori review remains. Note: art. 21 CT has not been expressly repealed and legal opinion is divided, but in practice prior authorisation is no longer required.
Proportionate geolocation, limited to working hours, with a private mode outside those hours
YesrequiredAccording to the CNPD, geolocation may not locate the worker nor monitor their performance, may not extend to breaks and rest periods, and the worker must be able to switch to private mode outside working hours. The worker's consent is not a valid legal basis.
CNPD, Deliberacao 7680/2014 (geolocalizzazione nel contesto lavorativo)
Impact assessment (DPIA) for tracking the location of workers
YesrequiredThe CNPD list requires an impact assessment for processing that allows tracking the location or behaviour of workers with an evaluation or classification effect.
Opinion of the workers' committee, where one exists
It dependsonly in certain casesWhere a workers' committee exists, its opinion must be requested.
The procedure, step by step
Inform workers of the existence and purpose of the surveillance (art. 20 CT).
Check the purpose: allowed only for the safety of people/property or particular needs of the activity, never to monitor performance.
If a workers' committee exists, request its opinion.
Carry out the impact assessment (DPIA) for location tracking.
Configure the system with data minimisation: no tracking of whereabouts, private mode outside working hours, limited retention.
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 (Comissao Nacional de Protecao de Dados)
https://www.cnpd.pt/cidadaos/participacoes/
https://www.cnpd.pt/cidadaos/participacoes/
Portugal has a single national authority, the CNPD; there is no regional breakdown.
Verified on June 15, 2026
CNPD, segnalazioni
https://www.cnpd.pt/cidadaos/participacoes/
https://www.cnpd.pt/cidadaos/participacoes/
Verified on June 15, 2026
The template to download
Download the free GPS privacy notice template for Portugal
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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A real case confirmed in court: the Lisbon Court of Appeal (2026) upheld the EUR 14,790 fine imposed by the ACT on a wine company that had installed GPS in a saleswoman's car and compared her routes with the daily reports of customer visits. The CNPD, by contrast, does not publish individual sanction decisions, so the ceiling remains the general GDPR one (Article 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 Portugal: what you need to stay compliant - GeoTapp. https://geotapp.com/en/resources/gps-workers-eu/portugal/Source: <a href="https://geotapp.com/en/resources/gps-workers-eu/portugal/?utm_source=citazione&utm_medium=referral&utm_campaign=risorse">GPS and worker monitoring in Portugal: 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
- Codigo do Trabalho, art. 20 (mezzi di sorveglianza a distanza)
- CNPD, Deliberacao 7680/2014 (geolocalizzazione nel contesto lavorativo)
- Lei 58/2019, art. 28 (relazioni di lavoro)
- CNPD, valutazione d'impatto sulla protezione dei dati
- CNPD, presentare una segnalazione
- 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.