Using Video Telematics Responsibly: Why a DPIA Matters

Video telematics is becoming an increasingly powerful tool to reduce accidents, improve driver behaviour and keep insurance costs under control. However, with this, the responsibility to take data protection seriously, also increases.

Video telematics systems capture personal data from drivers, passengers and other road users, meaning that their use within a fleet must be proportionate to their need. Therefore, it is essential to perform a Data Protection Impact Assessment (DPIA) before installing or changing systems within vehicles.

A DPIA is more than just legal compliance, but a tool that empowers an organisation to:

1. Design appropriate video telematics solutions

2. Protect driver privacy and build trust

3. Reduce legal and regulatory risk

4. Increase value from investment

 

Is a DPIA required?

Under Article 35 of EU and UK GDPR, organisations must complete a DPIA where data processing poses a high risk to individuals’ rights and freedoms. Additionally, the ICO states that surveillance requires a data protection by design and default approach and a DPIA is required where high risk is likely to individuals.

The Irish Data Protection Commission notes that a DPIA is required where processing involves evaluation or scoring, including profiling and predicting, location or movements. 

Rolling out fleet-wide cameras and telematics usually requires a DPIA by law, but more importantly it is a key tool for delivering safety, claims defensibility and a purposeful solution, without undermining the people monitored. 

 

What does a DPIA do and what does it require?

A Data Protection Impact Assessment (DPIA) is a risk assessment for personal data. It documents what data is processed, how it’s processed and identifies and reduces project risks. A DPIA requires the following: 

A description of the project
Documents why the system is needed, its benefits, who and what it applies to and system features. 

Security and access measures
Details protections, access rights and measures that ensure data accuracy throughout processing. 

Assessment of necessity and proportionality
Ensures telematics use is justified and minimally intrusive. 

• Identification and assessment of risks
• Evaluates impacts on individuals and the organisation at all stages of processing. 
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• Implementation of risk controls
  Documents measures to prevent or minimise risks, including technical protections, organisational measures and design considerations. 

A DPIA documents why and how video telematics is used and identifies how risks are managed. It demonstrates compliance to regulators and ultimately, can reduce the likelihood of regulatory fines even if something is unintentionally missed from the assessment.  

 

How a DPIA for video telematics benefits you...

You design the right solution
Ensures only necessary features are implemented. This delivers a justified, compliant and cost-effective solution.

You clarify purpose
Creates clear intent, ensuring the system is built for real needs and creates solutions that people actually use. 

You get better safety and risk outcomes
Risks are identified and mitigated before the project starts.

You get faster approvals and fewer internal battles
Aligns all stakeholders, reduces objections and ensures transparent use of video telematics. Early consultation and clear rules build driver trust and position cameras as driver protection rather than surveillance. 

You reduce regulatory and legal risk
Proves GDPR accountability and strengthens your position in legal or union challenges. 

 

What are the consequences of skipping a DPIA?

Not doing a DPIA isn't just skipping paperwork but instead increases the risk of problems for the organisation.

Greater regulatory and legal risk
Skipping a DPIA risks GDPR non-compliance, regulatory fines, costly changes and difficulty justifying decisions if investigated.

Weaker position in disputes and claims 
Video telematics is key to collisions investigations, insurance disputes and employment issues, but without prior privacy and fairness assessment, footage may be challenged as inadmissible. 

Damage to trust 
Without consultation, cameras can erode driver trust and increase resistance from employees. A DPIA encourages risk assessment and consultation with drivers or their representatives. 

 

How VUE can support your DPIA

As a long-standing provider of vehicle cameras, telematics and fleet risk management solutions, VUE is experienced in working with organisations that take compliance seriously.  

 When working with VUE as your video telematics partner, we can: 

• Provide clear and transparent technical information 
• Help you design privacy-conscious configurations 
• Align safety and privacy from the start 
• Support your team documentation and governance process 

VUE brings specialist knowledge, data protection and GDPR compliance, creating an effective and compliant solution for your business. To find out more, contact us today.

For further information and best-practice guidance, refer to the Information Commissioner’s Office (ICO) guide to Data Protection Impact Assessments.