Answering the Question Without Location
For each operational question, the option that collects nothing. Worth exhausting first, because the impact assessment will ask.
The proportionality test asks what less intrusive method was considered. Having a real answer requires knowing the alternatives exist.
Proof of attendance
Customer confirmation: a signature, a code, a tap on the engineer's device.
A photograph of the completed work, timestamped.
A job-completion step in the work management system.
All three prove more than a location event does — they show the work, not just the vehicle — and collect nothing about anyone's movements.
Where the customer is present, this is strictly better and it is frequently overlooked because the tracker was bought first.
Dispatch
Ask. A radio or a message asking who is free takes seconds and is how this worked for decades.
Self-reported status: available, on a job, travelling, on a break.
Which is less precise and entirely adequate for many operations, particularly where rounds are pre-planned rather than dynamic.
Location genuinely helps where dispatch is dynamic and dense. Where it is not, it is solving a problem that does not exist.
Mileage
Odometer readings at start and end, photographed.
Fuel card data, which many fleets already have.
Route distance from the job list, for pre-planned rounds.
Adequate for expenses and tax in most cases, and the automated version is a convenience rather than a necessity.
Lone worker safety
A check-in schedule by phone or message, with an escalation if missed.
A buddy system.
A dedicated alarm device that transmits position only when triggered, which is location but only at the moment of need.
The third is the better answer where risk is real, and it is a much narrower collection than continuous tracking.
Driver safety
Forward-facing camera without location.
Licence checks and driver training.
Vehicle maintenance, which affects collision risk more than most scoring does.
Using this in the assessment
Name each alternative you considered and why it was rejected, in terms of the purpose.
"The customer is not always present" is a reason. "The tracker was already installed" is not.
And run the test honestly: if a completion record answers every question you actually ask, the location system is collecting for questions nobody is asking — which is what a regulator examining proportionality will conclude too.
Write the rejections down
The proportionality section needs reasons, not a conclusion.
Name each alternative considered.
Say why it was rejected, in terms of the purpose.
"The customer is not always present" is a reason.
"The tracker was already installed" is not, and writing it down is what forces the question.
This is the section regulators have examined, and it is the one usually written thinnest.
An implementation prompt
During configuration, this team example can prompt questions about fields, ownership and output. Confirm current capabilities and document each plan, integration or policy assumption.
Independent reference
For an external point of reference, see the Information Commissioner's Office. Its data-protection guidance is a useful external check when comparing less intrusive ways to answer the same question.