L.C v Société d'Exploitation du Train Express Régional de Dakar (SETER)
Formal notice (mise en demeure): one month to declare the geolocation system, suspend its exploitation until conformity (including the vehicle-leasing company), and put rights procedures in place; publication ordered. CDP, September 2022.
The facts
An employee complained that the operator of the regional express train, SETER, had installed a geolocation device on his company vehicle without prior and formal information. SETER answered that the vehicles were leased and the lessor had installed the device, and that it did not collect location data. The CDP held that SETER determines the purposes of the tracking, using it to monitor journeys and staff presence, making it the data controller and the vehicle lessor its processor, so SETER should have completed the prior formalities, verified its processor's conformity, and informed employees of the system and its purposes.
Orders and outcome
The file was put to the plenary, which decided to put SETER on formal notice to end the breaches within one month. Dated 2022.
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