DPIA pack
For haulage operators using TrueMile's driver tracking · Last updated 29 July 2026
If you track your drivers' location, the law expects you to have written down what you collect, why you need it, what could go wrong and what you have done about it. That document is a Data Protection Impact Assessment, and it is your duty as the employer, not ours.
That is the bad news. The good news is that most of a DPIA is a description of how the software works, and we can answer that part for you. Everything in a green box is done. Everything in an amber box is a question only you can answer, because it is about your firm and your reasons.
Print this
Use your browser's print option and choose "Save as PDF". Fill in the amber sections, sign the last page, and keep it with your O-licence paperwork. Review it whenever you change how you use the tracking.
1 · Do you actually need one?
A DPIA is required where processing is likely to be high risk. The regulator treats tracking the location or behaviour of people, and monitoring employees, as exactly that. Continuous location tracking of drivers is both at once.
- You use the live map or driver tracking — yes, you need one. Work through this document.
- You use timesheets, walkarounds or defects but never tracking — you are still handling staff data, but it is far lower risk. A DPIA is unlikely to be required. Sections 2 and 6 are still worth completing.
- You only use the cost calculator and quotes, with no drivers on the app — no personal data of anyone else is involved, so no DPIA.
2 · What is being processed
What is collected: the driver's position, direction and speed, plus clock-on and clock-off times. Alongside that, depending on which features you switch on: their name, email address, phone number, walkaround checks and the signature drawn on them, defect reports, job photos they choose to upload, hours worked and booked holidays.
When location is collected: only while the driver is clocked on shift. Clocking off stops it immediately. The app displays a notice on the shift screen saying location is being shared.
How: from the TrueMile app on the driver's own phone, sent over an encrypted connection.
Who can see it: only people in your company account. It is never visible to another haulier, never published, and never sold.
How long it is kept: location history is deleted automatically after 90 days. Sign-in records, 90 days. Unaccepted invites expire after 14 days. Backups are kept 30 days, plus one month-end backup for a year. Everything else lasts as long as your account.
Who else is involved: Supabase (database and logins), Cloudflare (hosting, backups, email delivery), Stripe (subscription payments — card details never reach TrueMile), Resend (sending email), Google Firebase (push notifications to the driver app; it receives a device token, not your business data).
How many drivers are on the app, and are any of them under 18 or otherwise likely to need extra care?
Which features have you actually switched on? List them — tracking, timesheets, walkaround checks, holidays, and so on. A DPIA covering things you do not use is harder to defend, not easier.
3 · Why you need it, and whether it is proportionate
This is the heart of it, and the part an inspector or an unhappy driver will press on. You have to show the tracking achieves something real, and that you could not achieve it in a less intrusive way.
What is your reason? Be specific and honest. Good reasons tend to be operational: proving delivery times to customers, knowing which vehicle is closest to a job, evidence for a claim or a dispute, driver safety on remote runs, or supporting your tachograph and working-time records.
"Keeping an eye on them" is not a reason. If the honest answer is that you do not trust a particular driver, deal with that as a management matter, not by monitoring everybody.
Could you get the same result with less? Say why phone calls, delivery notes or tachograph data alone are not enough for what you described above. If they would be enough, you should not be tracking.
What is your lawful basis? For employers this is normally "legitimate interests", and you should write a short note of why your interest does not override the driver's privacy. Consent is usually the wrong choice here — an employee asked by their boss is rarely considered free to say no.
Proportionality measures already built into the software, which you can point to:
- Location is only collected on shift, never in a driver's own time.
- Clocking off stops collection immediately, and the driver controls that.
- The app tells the driver on screen that location is being shared.
- History is deleted after 90 days, so no long-term picture of anyone's life is ever built.
- Access is limited to your own company.
- There is no off-shift tracking feature, and none is planned — it was considered and deliberately not built.
4 · Consulting your drivers
You are expected to seek the views of the people being monitored, or record why you did not. This is usually the step people skip, and it is the one that causes grievances later.
How did you tell your drivers, and what did they say? A toolbox talk, a letter with the payslip, or a line in the handbook are all fine — write down which, and when. Note any concerns raised and what you did about them.
5 · What could go wrong
Set out the risks to your drivers — not the risks to your business. Here are the realistic ones for this kind of processing, with what is already in place against them. Add any that are specific to you, and score each as low, medium or high.
| Risk to the driver | Already in place | Your score |
|---|---|---|
| Being tracked in their own time | Collection only runs while clocked on; clocking off stops it at once | — |
| A permanent record of their movements | Automatic deletion after 90 days | — |
| Data seen by people who should not see it | Access limited to their own company; each company walled off from the rest | — |
| Data lost or leaked | Encrypted in transit and at rest; backups held with a separate company from the database | — |
| Used for a purpose they were never told about | Your job — see section 4 | — |
| Driver cannot get at their own data | Copy, correction and deletion requests supported; TrueMile assists you | — |
Any risks particular to your operation? For example drivers taking vehicles home, tramping and sleeping in the cab, or a yard where one person can see everyone's screen.
6 · What you will do about it
Technical measures provided by TrueMile: encryption in transit and at rest; per-company data separation enforced at the database; on-shift-only collection; automatic 90-day deletion of location history; two-factor authentication available on accounts; sign-in records kept for 90 days so unusual access can be spotted; automatic backups every six hours held with a separate provider.
Your own measures. Who in your firm can see the map, and does that need to be everyone? Who removes a driver's access when they leave, and how quickly? Where is your written notice to drivers kept? Who do drivers ask if they want a copy of their data?
7 · Sign it off
A DPIA is not finished until somebody accountable has signed it, and it should be looked at again whenever you change how you use the tracking.
Being straight with you
This is a starting point written by a haulier, not legal advice, and completing it does not by itself make you compliant. The parts about how TrueMile works are accurate and you can rely on them. The parts about your reasons, your drivers and your yard are yours, and they are the parts that actually matter if anyone ever asks. If you are running a sizeable fleet, an hour of a solicitor's time spent reading your completed version is money well spent.
TrueMile is a trading name of Joseph Copley. Questions about anything here — support@truemile.co.uk.
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