The Impact Assessment

General orientation, not legal advice.

Location monitoring of a workforce generally requires an assessment. The narrow shape of geofenced clock-in makes it one of the easier ones to write honestly.

Why one is needed

Systematic processing of location data about identified people, applied to a whole workforce.

Guidance on when an assessment is required lists systematic monitoring among the criteria, and an attendance check applied to everyone meets it.

Its absence has been treated as a breach in its own right, separate from anything the processing did wrong.

Write it before deployment. One written afterwards is a justification exercise and reads as one.

What to write

The purpose: verifying attendance at a defined workplace, to produce an accurate pay record.

What is collected: a position and accuracy figure at the moment of a deliberate action, nothing between.

The legal basis, with the balancing test written out.

Who has access, and when.

Retention, per category — coordinates short, attendance record long.

The risks: a refused punch causing unpaid time, a position revealing a home address if someone punches from home by mistake, and the effect of being checked.

The proportionality section

This is where it is decided, and where deployments fail.

Name the less intrusive alternatives you considered: wifi visibility, a beacon, an NFC tag, a fixed terminal, a code on a screen.

Say why each was rejected, in terms of the purpose rather than convenience.

"No fixed site to put a beacon in" is a reason. "The geofence product was cheaper" is not, and writing it down forces the question.

For a fixed workplace the alternatives are genuinely strong, which makes this section harder to write than people expect — and that difficulty is the point.

What the narrow design buys you

Say explicitly that the check is initiated by the worker, happens once, and stores one point.

That there is no background collection, and how that is verifiable.

That coordinates are deleted on a short schedule.

These three sentences distinguish the deployment from the continuous-tracking cases that produce enforcement, and they belong near the top.

Keeping it alive

Review after any vendor release, because a feature arriving enabled makes the document inaccurate.

Review when a radius changes materially.

Date it, version it, record who decided.

And check whether it changed anything. An assessment that concluded the original plan was perfect has documented a decision rather than examined one.

Say what the narrow design buys

Three sentences that belong near the top.

The check is initiated by the worker.

It happens once and stores one point.

There is no background collection, and here is how that is verifiable.

These distinguish the deployment from the continuous-tracking cases that produce enforcement, and burying them in an appendix wastes the strongest part of the design.

An implementation prompt

During configuration, the connected-work reference 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 ICO resources. Consult the current material directly because technical and legal details can change.