Geolocation and workers' privacy
Can I make geolocation mandatory? Under what conditions?
Yes, technically. Legally, you must have a specified purpose and a valid legal basis, documented in writing, and check that the measure is proportionate.
Before enabling geolocation, you must in particular:
- document the purpose and the legal basis;
- check that a less intrusive solution would not suffice (Locations without coordinates, a clocking station linked to the site);
- carry out a data protection impact assessment where one is required;
- inform workers in advance.
If location is mandatory, a clocking without a position is rejected: a worker who refuses permission in their browser, or who has neither a network nor GPS, will not be able to clock in (see “Why can't my worker clock in?”). Plan an alternative. If in doubt, consult your data protection adviser or your social secretariat.
Reference : clause 7.3, clause 7.2 of the terms and conditions