Fleet telematics, dashcams and vehicle tracking

• Regulation (EU) 2016/679 — GDPR, Articles 27 and 88
• Directive 2014/53/EU — Radio Equipment
• Regulation (EU) 2023/2854 — Data Act for vehicle-generated data
• Regulation (EU) 2024/2847 — CRA

Who has to appoint one

Providers outside the Union selling tracking hardware or telematics services to fleets operating in the EU. Location data of drivers is personal data about workers, which is one of the most sensitive processing contexts in the Union and is regulated additionally by national employment law under Article 88.

Thresholds and exemptions

None. Even a small fleet triggers the obligations, and works council consent is required in several member states regardless of the legal basis chosen.

What must appear on the label

CE marking and the usual hardware markings for the device. For the service, the representative's identity in the privacy notice and clear driver-facing information about what is tracked, when, and who sees it.

Marketplace fields

Fleet customers require a data protection impact assessment and a works council-ready description before deployment. Dashcams sold to consumers face separate national rules, since several member states restrict continuous recording of public roads.

Documentation you must hold

Article 30 records, Article 28 terms with fleet operators, the Article 27 designation, a data protection impact assessment covering employee monitoring, retention schedules distinguishing operational from evidential use, and the transfer mechanism. Hardware documentation as for any radio product.

Standards and testing

Radio, EMC and vehicle electrical environment testing for the device, and where the system infers driver behaviour, accuracy evidence, because scoring drivers on inferred data has been challenged successfully.

Language requirements

Driver information in the language of the drivers, and customer documentation in the language of the market.

When it applies

The representative before processing begins. The Data Act's provisions on access to vehicle-generated data have applied since September 2025 and reshape who may obtain what from connected vehicles.

How long records are kept

Location data only for the operational period necessary, typically days or weeks rather than years, unless a specific evidential purpose justifies longer. Continuous location histories of workers retained indefinitely are the most frequently penalised design.

What happens if you do not comply

Up to €20 million or 4% of turnover. Employee monitoring cases attract consistent enforcement across the Union, and several authorities have banned continuous tracking outside working hours outright.

Who enforces it

Data protection authorities, labour inspectorates in some member states, and market surveillance for the hardware.

Where the boundary lies

Private use of a company vehicle is where cases are lost: tracking that continues outside working hours, or that cannot be paused, has been found unlawful repeatedly. Dashcams add a second layer, because footage of other road users is processing by the fleet and, in some designs, by the vendor.

Questions we are asked

Can we track vehicles continuously?

During working time with a proper basis and transparency, usually yes. Outside working hours, or without a way to pause private use, authorities have repeatedly found it unlawful.

Is a dashcam legal in the EU?

It varies by member state. Several restrict continuous recording and permit only incident-triggered retention, and the operator is the controller for the footage.