Privacy worksheet · Free Word file

DPIA and legitimate-interest worksheet for GPS trackers and driver cameras

Think through the privacy risks of GPS trackers, DSM driver cameras and after-hours tracking before you switch them on. Nine steps. You write the answers. The worksheet never decides for you.

Free: enter your name and e-mail and we send you the file. Optional: tell us the size of your camera project and we follow up with the right questions.
  • 9 steps in one file
  • Risk scoring guide
  • No pre-filled conclusions
What's inside

A scoring guide you can change, and nine steps to fill

Step 5 scores each risk for likelihood and severity from 1 to 3. This grid is Tracom's suggestion, not a legal scale. Change it to fit your policy.

  • Low: 1 to 2
  • Medium: 3 to 4
  • High: 6 to 9
Likelihood \ SeverityLowMediumHigh
HighMedium3 x 1 = 3High3 x 2 = 6High3 x 3 = 9
MediumLow2 x 1 = 2Medium2 x 2 = 4High2 x 3 = 6
LowLow1 x 1 = 1Low1 x 2 = 2Medium1 x 3 = 3
The steps

From screening to sign-off

  1. Screening

    Ten yes, no or unsure questions. They show whether the processing looks like the kind that needs a written assessment.

  2. Describe the processing

    One row per system: data, whose data, recipients, hosting, retention.

  3. Consultation

    Who you asked, what they said, what you changed.

  4. Necessity and proportionality

    The problem, the lighter alternatives you considered, and data minimisation choices.

  5. Risks

    A register with prompts. Score each risk for likelihood and severity.

  6. Measures

    A measure, who is responsible and a date for each risk, and what it does to the risk.

  7. Residual risk and decision

    What remains, and a decision you tick yourself.

  8. Legitimate-interest assessment

    Purpose, necessity and balance tests, with your own conclusion.

  9. Approval and review

    Five sign-off lines and a review date.

What a DPIA is

A data protection impact assessment is a written look at what could go wrong for people before you start a processing activity, and what you will do about it. For a fleet it means describing what trackers and cameras record, asking if it is needed, and deciding on safeguards.

When to do one

Saudi rules (Implementing Regulations, Article 25) require an assessment for large-scale or regular processing with continuous monitoring, and UAE law (Decree-Law 45 of 2021, Article 21) asks for one for modern technologies with a high privacy risk. Driver tracking and DSM cameras fit that picture. Even when the law does not require one, a signed worksheet shows that you thought first. Source and date checked: 3 Nov 2026. Ask legal how it applies to you.

The three tests of legitimate interest

  • Purpose: is the interest real, lawful and clearly stated?
  • Necessity: do you need this data and this level of intrusion to reach it?
  • Balance: do the drivers' rights and expectations outweigh your interest, once safeguards are counted?

Check with legal that this basis is open to you. Article 16 of the Saudi Regulations requires a documented assessment before processing and does not allow the basis for sensitive data.

Who should fill it in

Do not fill it in alone. Put fleet operations, HR, IT or security and the data protection contact in one session, and ask drivers or their representatives. Large customers and auditors often ask to see the finished worksheet when you propose a camera project.

Limits of this worksheet

It gives structure and prompts. It reaches no conclusion, it does not know your devices or your platform, and it does not say that your project meets any law.

Related Tracom solution

Facts about the devices for step 2

Step 2 asks what each system records. Take those facts from the device datasheet and your platform settings. If you plan Tracom ST100 or M1N, ask us for the list of what the device and portal can record.

  • ST100. An IVMS GPS tracker.
  • M1N MDVR. A mobile DVR that works with cameras.
  • SCMS portal. Manage devices in one place.
  • Tamper-proof security. Helps protect the device and its data.
Questions

Worksheet questions, answered

Planning a camera project? Talk to Tracom.

Is a DPIA mandatory?

It depends on the law and on your processing. Article 25 of the Saudi Regulations and Article 21 of the UAE Decree-Law name continuous monitoring and new or modern technology among the cases that need one. Your legal adviser confirms. The worksheet does not decide.

Can I rely on legitimate interest for DSM cameras?

Ask legal. Article 16 of the Saudi Regulations does not allow it for sensitive data, and face analysis may count as sensitive. The worksheet makes you write the question down.

Who signs it?

Step 9 has five lines: assessor, responsible for the project, data protection contact, legal reviewer and approver. Remove lines you do not have.

Why are there example rows and no scores?

Grey rows are prompts. Scores and conclusions must come from you, because they depend on your fleet.

Is there an Excel version?

No. This is a Word file in English and Arabic, because most answers are text.

What is Tracom's role?

Tracom makes tracking devices and video recorders. It does not complete your assessment, choose your basis or give legal advice.

Next step

Plan the cameras with the risks in view

Bring your finished worksheet. We will show how the M1N MDVR and its camera settings can fit your safeguards.

Related tools and templates

Keep going on driver privacy

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