Formal notice (mise en demeure): correct all breaches within one month and suspend the processing until cdp authorisation is obtained. CDP, March 2025.
processing without prior formality/authorisation (vehicle geolocation), unlawful collection of personal data, infringement of the data subject's privacy
Provisions cited
Loi n°2008-12 du 25 janvier 2008
Outcome
formal notice (mise en demeure): correct all breaches within one month and suspend the processing until CDP authorisation is obtained
The CDP received a complaint from an employee, Mr A.B.T, against Eiffage Rail Dakar (ERD) concerning the geolocation of his company vehicle. The CDP sought explanations from ERD's management, which responded, and the file was put to the plenary session. The plenary found that the geolocation processing had been deployed without the prior formality required by Law n.2008-12 of 25 January 2008, that personal data had been collected unlawfully, and that the data subject's privacy had not been respected. It issued a mise en demeure requiring ERD to correct all the breaches found within one month.
GEOLOCATION · EMPLOYEE MONITORING · FORMAL NOTICE
Cite this decision
CDP (Senegal), Eiffage Rail Dakar (ERD), Avis Trimestriel N°01-2025 (mise en demeure ERD), enforcement notice of March 2025. African Data Protection Enforcement Tracker, Law Lab Africa Research, https://research.lawlab.africa/tracker/senegal/cdp/2025/eiffage-rail-dakar-geolocation-formal-notice/ (accessed 30 August 2026).