What an Investigation Would Ask For
Three situations examine this programme, each asking for different things, and most of it cannot be produced afterwards.
Obligations · Procedure
General orientation, not legal advice.
A behaviour programme is examined in a grievance, a data protection complaint and occasionally after a serious collision.
A grievance or tribunal
The events relied on, with full context and the whole video buffer.
The thresholds in force at the time, which requires them to be versioned.
Evidence the system was working on that vehicle: calibration, no known fault, mounting verified.
Coaching offered before escalation.
Comparators: who else, what happened to them.
A case missing any of these is the case that is overturned.
A data protection complaint
The lawful basis with the balancing test written out.
The impact assessment, dated before deployment.
Consultation records where required.
What is collected, retention per category, and evidence deletion ran.
The access log, which is the document that answers "who has been watching me".
After a serious collision
The incident data, preserved by a hold triggered at report.
Hours worked and the schedule that day.
Vehicle condition and maintenance history.
Prior near-miss reports at that location.
An investigation that examined only the driving will be asked why.
What cannot be produced afterwards
Thresholds as they were, without versioning.
Whether a device was calibrated at the time.
The access log, if viewing was never logged.
Whether coaching happened, if it was a conversation nobody recorded.
Each costs nothing to capture continuously and is impossible to reconstruct.
The self-audit
Take one coaching case and one disputed event from last quarter.
Assemble everything a challenge would ask for.
Time it.
Whatever you cannot produce, the other side would also not find — and in a grievance that gap works against you, because the burden of showing a fair process sits with the employer.
What to keep permanently
Threshold versions with dates.
Calibration records per device.
The assessment, the balancing test and the consultation record.
Access logs.
And the purpose statement, so a later use outside it is visibly a change.
Version the thresholds
A small record with a large consequence.
Each threshold, per vehicle type, with the date it changed.
Because a challenge to an event from eighteen months ago cannot be assessed without knowing what the threshold was then.
One line per change, kept indefinitely, and it costs nothing until it is the only thing that answers the question.
Connect policy and data
The choices in this note can be compared with open the record-flow reference. Keep the written purpose in control and enable only the information needed at this boundary.
Independent reference
For a thematic point of reference, see the International Organization for Standardization. Consult the source directly because technical, operational and legal details change.