The Legal Basis

General orientation, not legal advice; requirements differ substantially by jurisdiction.

This is among the more intrusive things an employer does, and the paperwork is proportionate to that rather than to the cost of the hardware.

Why it is harder than vehicle data

It describes conduct rather than a machine.

It is continuous during working time rather than occasional.

Video of a person's face and body is a further step, and depending on processing may engage biometric rules.

Which means the justification has to be specific to a risk you can evidence, not to a general interest in safety.

The basis

Consent is weak in employment because it cannot be freely refused, which rules out the basis most vendor material assumes.

Legitimate interests is the usual route, with a balancing test written out: the interest, why this processing is necessary for it, the effect on drivers, and why the interest is not overridden.

Legal obligation applies in narrow cases — regulated transport, specific safety duties — and does not cover a general behaviour programme.

Write the balancing test. An unwritten one has not been conducted.

The impact assessment

Likely required: systematic monitoring of individuals, at scale, on a continuing basis.

Its absence has been treated as a breach in its own right.

The proportionality section decides it, and it must name the less intrusive alternatives considered: vehicle-only telematics, forward-facing video only, route and schedule intervention, training without monitoring.

Saying why each was insufficient is the argument. "The package included it" is not one.

What people must be told

What is measured, when, and by which method.

Whether video records the cab.

Who can see it and in what circumstances.

Retention.

Whether it feeds performance or discipline, which is the question they actually have.

And how to see their own data, which is a right and is also the cheapest error correction available.

Purpose limitation

Collected for safety, used for safety.

A system deployed on a safety justification and used for timekeeping, break monitoring or productivity has changed purpose, which is both a compliance problem and the fastest way to lose the workforce.

Write the limitation down and name who enforces it.

The retention question

Event data has a short operational life: coaching happens within days.

Video shorter still, with an incident hold.

Scores and their inputs long enough to show a trend, which is quarters rather than years.

Defaults in this category are generous, and a fleet holding a year of cab footage has acquired an obligation nobody decided on.

Name the alternatives you rejected

The section that decides the proportionality argument.

Vehicle-only telematics. Forward-facing video alone. Route and schedule intervention. Training without monitoring.

For each, why it was insufficient for the risk you identified.

"The package included it" is not a reason, and an assessment that does not address the alternatives has not examined proportionality at all.

Connect policy and data

The choices in this note can be compared with employee activity tracking with a defined purpose. 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 European Data Protection Board. It provides useful context beyond supplier documentation and should be checked in its current form.