Skip to main content

Using Tracker lawfully: a guide for organisations

For organisations · Version 0.1 draft · Not yet in force

Draft for legal review. This is guidance, not legal advice. Take your own advice for your circumstances.

You're the controller of your customers' and operatives' data in ROCC Tracker. Tracker is designed to make compliance straightforward, but some steps are yours.

1. Decide your lawful basis​

For most organisations this is legitimate interests: keeping residents informed about visits, running visits efficiently, and helping residents check who's at the door. Record a legitimate interests assessment.

  • Operatives: don't rely on consent. Employees can't freely refuse their employer, so consent is rarely valid.
  • Customers: where visits are part of a tenancy or repair contract, contract may also apply.

2. Tell people​

  • Customers: link your own privacy notice from Tracker's settings, or use the visit tracking notice template, which the tracking page shows filled in with your details.
  • Operatives: before they start using the app, give them the operative notice, or add its content to your staff privacy notice. Explain when location is shared, who sees it, and how long it's kept.
  • Set a privacy contact in Tracker's settings, so both notices name the right person.

3. Carry out a DPIA​

Tracking workers' locations is likely to need a data protection impact assessment, especially with background location or photos shown to customers. The ICO's guidance on monitoring workers covers what to consider. Points that usually help:

  • location only between setting off and arriving;
  • short trail retention;
  • customers see only their own visit;
  • photos shown only during the journey;
  • operatives can see when sharing is on.

4. Be clear about what it isn't for​

If you might use journey data for anything beyond informing customers and planning visits, such as investigating a complaint, decide that up front, tell operatives, and include it in your assessment. Covert monitoring needs exceptional justification.

5. Keep only what you need​

Set how long you keep visit records, the message log and location trails under Settings → Retention. Tracker deletes them automatically after that, and your notices show the periods you chose. Don't put health, disability or vulnerability details into visit references or names. If you need to flag vulnerable residents, talk to us first.

6. Photos​

Use a recent, recognisable work photo, ideally taken for this purpose. Tell operatives why it's shown, and listen to objections. You can remove a photo at any time.

7. Rights requests​

Use the admin or API to find, export, correct or delete a person's data. Tell ROCC at [privacy@ROCC domain] if you need help.