Driver data and labour control limits

The decision on what to measure about a worker is from the employer, not ours. But we build the tool, know its limits and know that most of the conflicts that telematics produces do not come from technology but from setting it up without considering the work framework. To keep it quiet so that the sale is simpler would be to transfer to our client a risk that we see and he does not.

With respect to drivers' data, Drometra acts as processor: it processes the data on behalf of the customer that employs them, following its instructions, and does not use it for its own purposes.

On this basis, the Labour Directorate has built a consistent doctrine on the mechanisms of audiovisual control and positioning. Its criteria can be summarized in four cumulative requirements: that the system is objectively justified by technical requirements of the production process or for safety reasons; that it is general and impersonal, and not a follow-up to a person; that the control of the worker's activity is a secondary result and not the purpose; and that it is incorporated into the internal regulations of order, hygiene and safety, and is known to the workers.

As of 1 December 2026, above all, Act No. 21.719, on the basis of legality, the duty of information, minimization, the time limits for conservation and the right to exercise, is superimposed. To comply with the labour framework does not exempt the framework of data protection and vice versa.

The table summarizes the usual reading of the framework for the most common uses of telematics. It includes uses that Drometra does not offer today, because the customer may combine our platform with other tools and it is useful for them to know the full criteria.

This is the data that the Dromivia field app and the console process about a driver. The app's technical details are in the Dromivia privacy notice.

• First name in tracking: the tracking page the recipient receives shows only the driver's first name and an approximate position (the center of a cell of about 300 meters) during the last leg.
• Local diagnostics: the app stores a technical log on the phone of up to 7 days, with no recipient data and with rounded coordinates. It only leaves the phone if the driver decides to share it.
• On sign-out: the workday's positions are deleted from the phone; when the device is unlinked, everything the app stored locally is deleted.
• Human review: no platform feature makes decisions about a driver. Any disciplinary measure is a decision of the employer, which must be based on verified facts and respect the worker's right to give their account.

For the internal regulations, we provide the customer with a precise technical description of what each module captures, so that it can draft its clause based on real data and not on a rough idea.

• You have the right to know what is recorded about you, for what purpose, for how long and who can see it.
• You can request access to your data and a copy of it, including your positions and the proofs of delivery that involve you.
• You can request rectification of an erroneous record: a misattributed delivery, a misassigned workday.
• You can object to a treatment that exceeds the stated purpose.
• You can claim with the Personal Data Protection Agency, and with the Labour Inspectorate if the problem is of labour control.

The application goes to your employer, who is responsible. If you don't know who to address it to or you don't get an answer, write to [email protected]: we identify the person responsible and transfer your application within 5 working days, confirm that we did it, and we don't inform him anything beyond what is necessary to process it.