Subcontractors and Self-Employed Drivers
Tracking people who are not your employees raises a question about their status that the tracking itself can answer badly.
Field operations run substantially on subcontractors, and applying an employee tracking system to them creates a problem beyond privacy.
The status question
Control over how and when work is done is a central indicator of employment in most status tests.
Continuous location monitoring is control, and it looks like it to a tribunal or a tax authority.
Requiring a tracker in a self-employed contractor's own vehicle, dictating routes, and monitoring their movements through the day are the facts these cases turn on.
Which means a tracking deployment can undermine the status the contract asserts, with consequences in employment rights and in tax.
Take advice where the exposure matters, because this is not a privacy question and the privacy analysis will not surface it.
Their vehicle or yours
Your vehicle, supplied to them: you may track the asset, with the same proportionality analysis as anywhere else.
Their vehicle: a much weaker position. Several jurisdictions restrict or criminalise placing a tracker on a vehicle you do not own, and consent from someone economically dependent on you is not a strong basis.
Their phone: weaker still.
The cleanest arrangement is to ask for the outcome rather than the location — confirmation of attendance from the customer, a job completion record, a photograph of the work.
What contractors should provide
Proof the job was done, which is the commercial interest.
Arrival confirmation, if the customer contract requires it.
Not: their working pattern, their route, their movements between your jobs and someone else's.
That last point matters. A contractor working for two firms should not have one firm tracking their work for the other, and a continuous tracker does exactly that.
Practical arrangements
A job-completion app that records attendance at the point of work, with no background collection.
Customer confirmation, which proves attendance more directly and collects nothing.
Geofence events only, if location is genuinely needed, with no trail between jobs.
Written into the contract as a specific requirement rather than imposed through a platform.
What to watch
Contractors held to employee processes — required schedules, route direction, monitoring during the day — which is the drift that produces status claims.
Long engagements with one firm, which is itself a status indicator.
A tracker that runs when they are not working for you, which is both a privacy and a competition problem.
Review annually, because these arrangements drift toward employment without anyone deciding to change them.
Ask for the outcome, not the location
The arrangement that avoids both problems at once.
Customer confirmation of attendance proves what you need commercially.
A job completion record proves the work.
Neither collects anything about where the contractor went between your jobs and someone else's.
And neither looks like control over how and when work is done, which is the status indicator that makes this more than a privacy question.
Connect policy to configuration
The practical choices behind this note can be compared with freelancer time tracking software. Keep the written purpose in control of the setup, enable only the data needed and review the result with affected workers.
Independent reference
For an external point of reference, see the GOV.UK service. Check current official guidance on employment status and responsibilities rather than relying on a label in the contract.