On 15 April 2021, the Commission Nationale pour la Protection des Données (“CNPD”), the Luxembourg Data Protection Authority, published new guidelines on the geolocation of company vehicles made available to employees (the “Guidelines”).
The use of company vehicles and their subsequent geolocation involves the processing of personal data. Therefore, the CNPD raises certain data protection questions and risks for the privacy of employees and states again that the geolocation of vehicles made available to employees has always to be considered as processing of personal data for surveillance purposes within the meaning of Article L. 261-1 of the Luxembourg Labour Code.
In the Guidelines, the CNPD reiterates some of the main principles and obligations applicable to the geolocation of employees with regard to the existing legislation on the protection of personal data.1
The entire Guidelines are available on the website of the CNPD at https://cnpd.public.lu/fr/dossiers-thematiques/geolocalisation-vehicules.html.
For more information on the process to be followed before implementing surveillance measures at the workplace such as video-surveillance, telephone recordings, geolocation, etc. please contact our ICT, IP, media and data protection team: