UK, Information Commissioner’s Office, 28 February 2024, GPS Tracking Pilot

Case Overview

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CountryUnited Kingdom

Deciding BodyData Protection Authority

AreaMigration

UserPublic

Case NameGPS Tracking Pilot

Authority (English)Information Commissioner's Office

TechnologyData Extraction and Analysis

ProviderPrivate

Decision Date28 February 2024

Authority (Original)Information Commissioner's Office

Grounds for DecisionNational Law

Legal RequirementProportionality, Transparency, Accountability, Purpose Limitation

The Home Office implemented the Satellite Tracking Services GPS Expansion Pilot in 2022, extending it for 18 months to use GPS ankle tags as a condition for immigration bail. This pilot targeted individuals arriving in the UK via dangerous routes and processed under the detained asylum casework (DAC) procedure. Despite the pilot ending in December 2023, the Home Office continued processing and sharing the collected GPS data, which included individuals’ location and movement information. In February 2024, the Information Commissioner’s Office (ICO) issued an enforcement notice and a warning letter to the Home Office. The notice ordered updates to internal policies, access guidance, and privacy information, while the warning stated that any future similar data processing would breach data protection laws and attract enforcement action.

The ICO concluded that the pilot failed to sufficiently assess the necessity and proportionality of continuous GPS monitoring and did not explore less privacy-intrusive alternatives. Significant privacy concerns were raised, with the Commissioner noting inadequate justification for the intrusive nature of GPS tracking. Recommendations were made for the Home Office to enhance its Data Protection Impact Assessment (DPIA) processes, improve transparency in data handling practices, and consider less intrusive monitoring methods.

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Further notes on contested technology

  • → Non-AI Technology
  • → The technology has been halted

Author of the case note

Ximena Pérez Almaraz