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
