There are numerous services that allow the user’s location to be determined. The so-called geolocation can be done via the IP address assigned by the Internet provider or via the mobile network. Determining the position of an Internet or mobile phone user can be very attractive or even necessary for a company, organization or institution to use this information for advertising purposes, for aspects of personal security, for improving IT security or for law enforcement by creating movement profiles. Positioning options such as GPS or location-based services in mobile communications allow the location and time of the cell phone to be recorded depending on the radio cells of the mobile service provider. Such location options are now used in many areas, e.g. for navigation systems or in emergency call location systems of rescue control centers. However, the technology is also used by employers to locate their employees and thus for monitoring purposes. This raises the question of the extent to which such information is subject to data protection regulations. Decision-makers and other responsible parties should therefore inform themselves about what needs to be taken into account if they plan to use such tracking technology.


Our law firm offers the following services on the topic of geolocation:

  • Data protection law and technical expert opinions on the use of geolocation
  • Technical-organizational measures for the use of geolocalization
  • General IT security measures in the use of geolocalization
  • Use of pseudonymization and anonymization in geolocalization
  • Preparation of the required list of processing activities (VVT)
  • Creation and conclusion of order processing contracts with external service providers
  • Conducting the legally required data protection impact assessment
  • Legal assessment of the collection, analysis and transmission of geolocation data to third parties, authorities, etc.
  • Creation of a concept for the storage and deletion of geolocation data
  • Creation of a company policy, works agreement or service agreement on the use of geolocation
  • Performance and behavior control in the context of geolocation
  • Geolocation in Wi-Fi networks
  • Advice on data protection law when using geolocation for (company) cars, forklifts, cell phones and for monitoring people (movement profiles)
  • Creation of work and organizational instructions for employees on how to deal with geolocation measures
  • Creation and implementation of data protection and IT security training on geolocation measures