What Personal Data Does a Logistics Company Process
Logistics companies process a broad spectrum of personal data:
Driver and employee data:
- Identification data (name, ID number, driver’s license)
- GPS and telematics data (location, speed, driving/idle time)
- Tachograph data (working time, breaks, rest periods)
- Video monitoring (cabin cameras, warehouse cameras)
- Health data (occupational health exams, alcohol testing)
Customer and partner data:
- Sender and recipient contact details
- Delivery addresses (often personal data of individuals)
- Cargo data (including sensitive — e.g., pharmaceuticals, high-value goods)
- Order and transaction history
Subcontractor data:
- Company and contact person details
- Subcontractor driver data (for license verification)
- Financial data (invoices, settlements)
GDPR requires that each category has a defined legal basis, purpose, and retention period.
Driver GPS Monitoring — How to Reconcile with GDPR
Fleet GPS monitoring is a key tool in logistics, but also one of the most controversial from a GDPR perspective.
Permissible GPS monitoring purposes:
- Cargo and driver safety
- Route optimization and operational efficiency
- Customer contract fulfillment (ETA, proof of delivery)
- Transport regulation compliance
GDPR requirements for GPS monitoring:
- Legal basis — legitimate interest (Art. 6.1.f) with a documented balancing test
- Transparency — the driver must be informed: what is monitored, for what purpose, who has access, how long data is stored
- Minimization — collect only data needed for the purpose (you do not need a position every 1 second if every 5 minutes suffices)
- DPIA — Data Protection Impact Assessment is required for systematic monitoring
- Retention limitation — GPS data deleted after purpose fulfillment
Mistakes to avoid:
- GPS monitoring outside working hours (privacy violation)
- Using GPS data for employee evaluation without legal basis
- Failing to inform drivers about monitoring scope
- Unlimited retention of location history
Technical Data Security in Logistics
GDPR requires “appropriate technical measures” (Art. 32). For logistics companies:
TMS/WMS systems:
- Encryption of databases containing personal data
- Role-based access control (RBAC)
- Access logging for customer and driver data
- Regular updates and vulnerability scanning
Telematics and IoT:
- Encrypted connection between vehicles and data center
- Telematics device authentication
- GPS spoofing and data manipulation protection
- IoT network segmentation from core IT
Integrations and EDI:
- Data encryption in transit (TLS 1.2+)
- API authentication with partners
- Data minimization in partner transmissions
- Data processing agreements with each partner processing data
Infrastructure:
- Firewall and WAF protecting web systems
- MFA on administrative accounts
- 24/7 security monitoring
- Backup with encryption and recovery testing
Data Subject Rights — How to Implement Them in Logistics
Right of access (Art. 15) A driver or customer can request information about processed data. The company must provide: GPS data, order history, tachograph data — within 30 days.
Right to rectification (Art. 16) Correction of inaccurate data — e.g., incorrect delivery address, incorrect driver data.
Right to erasure (Art. 17) Limited in logistics — much data is subject to mandatory retention (tax regulations, transport regulations, tachograph). The company must clearly communicate which data can be deleted and which cannot.
Right to data portability (Art. 20) A driver can request export of their GPS and tachograph data in a machine-readable format.
Right to object (Art. 21) A driver can object to GPS data processing based on legitimate interest. The company must demonstrate overriding legitimate grounds or cease processing.
Incidents and Breach Notification in Logistics
The most common data breaches in logistics companies:
- Customer database leak from the TMS system
- Unauthorized access to driver GPS data
- Ransomware attack encrypting operational data
- Loss of an unencrypted laptop with customer data
- Subcontractor security breach with data access
In every case, the company must:
- Report the breach to the supervisory authority within 72 hours
- Notify affected individuals (if high risk)
- Document the incident and actions taken
We recommend developing an incident response procedure as part of a security audit — a ready plan allows meeting the 72-hour window.
GDPR Fines for Logistics Companies — Precedents
- TNT Express (FedEx) — NotPetya costs: EUR 400 million (including data breach losses)
- Royal Mail UK — GBP 100,000 fine for sending marketing emails without consent
- Deutsche Post — supervisory authority investigation for voter data processing
- Transport companies in Poland — fines of PLN 10,000-50,000 for missing processing agreements and failing to inform drivers
Fines are increasing, and supervisory authorities are increasingly auditing the transport and logistics sector.
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