Tracking Service Vehicles In Luxembourg: Data Privacy Pointers For Employers

The Luxembourg data protection authority, the CNPD, recently fined an employer for failing to comply with the GDPR in its use of geolocation devices when tracking service vehicles. The decision highlights some key learning points for employers.

On 8 April 2021, the Luxembourg National Commission for Data Protection (CNPD) imposed a fine of EUR 2,800 on an employer whose use of geolocation devices violated the GDPR.

This decision provides extremely useful clarification on how the supervisory authority applies the provisions of the GDPR and the law of 1 August 2018 on the organisation of the National Commission for Data Protection and the General Data Protection Regime (the 'Law of 1 August 2018') and provides an opportunity to provide employers with some practical recommendations.