DPDP Act Compliance for Logistics and Supply Chain Companies in India: GPS Tracking, Telematics and Workforce Data Risks

Posted On - 12 February, 2026 • By - Aniket Ghosh

Introduction: Data Governance in Motion

India’s logistics sector runs on precision, speed and visibility. From fleet optimisation systems to warehouse access controls and last-mile delivery apps, operational efficiency increasingly depends on granular, real-time data. What is often viewed as infrastructure data, however, frequently contains personal information about drivers, workers, customers and business partners.

The Digital Personal Data Protection Act, 2023 and the accompanying Rules bring this data ecosystem squarely within a structured compliance regime. For logistics and supply-chain businesses, the challenge is not whether data can be used, but how it is governed ensuring that tracking, monitoring and analytics remain proportionate, transparent and legally defensible in a high-volume, multi-party environment.

Applicability of the DPDP Act to Logistics and Supply Chains

A. Who in the Logistics Sector Is Covered?

The DPDP Act applies to any organisation that processes digital personal data in the course of its operations. In the logistics ecosystem, this includes transport companies, fleet owners, 3PL and 4PL providers, warehouse and fulfilment centres, courier services, e-commerce logistics arms and even port or airport operators. Supply-chain technology providers offering tracking, telematics, TMS or WMS platforms are also within scope. Both Indian entities and foreign companies handling the personal data of individuals in India are covered by the law.

B. Role Allocation: Fiduciaries and Processors

In most cases, the logistics operator will be the data fiduciary because it decides what personal data is collected, why it is used and with whom it is shared. Technology vendors such as GPS or telematics providers typically function as data processors, but legal responsibility ultimately rests with the operator. Large companies that monitor continuous location and performance data at scale may face heightened compliance obligations and could be classified as Significant Data Fiduciaries under the DPDP framework.

Nature of Personal Data in Logistics Operations

A. Driver and Delivery Personnel Data

Logistics businesses process:

  • Identity and KYC documents
  • Driving licence and vehicle details
  • Real-time GPS location data
  • Speed, braking, idling and route behaviour
  • Attendance, productivity and performance metrics

Location data, when continuously tracked, is among the most intrusive categories of personal data due to its ability to reveal habits, routines and private life.

B. Warehouse and Contract Labour Data

Warehouses process:

  • Biometric attendance records
  • Shift, productivity and error rates
  • CCTV footage
  • Contractor and migrant worker records

Such data often involves power imbalance, making consent legally fragile.

C. Customer and Recipient Data

Supply chains also process:

  • Names, addresses and phone numbers
  • Delivery preferences and timing
  • Proof-of-delivery images and signatures

Even where customers are not the primary client (e.g., B2B logistics), their data remains protected under the DPDP Act.

The DPDP Act requires consent to be free, informed, specific and capable of withdrawal. In the logistics sector, this standard is difficult to meet in practice. Drivers cannot meaningfully refuse GPS tracking, warehouse staff cannot opt out of attendance systems, and customers must share address details to receive deliveries. In such situations, consent is often not truly voluntary, making it a weak legal foundation for core operational processing.

Most data processing in logistics is better justified on grounds of contractual or operational necessity such as fulfilling delivery obligations, ensuring safety or maintaining route efficiency. However, necessity has limits. Data collection must remain proportionate, tied to a clear purpose and retained only as long as required. Using operational data for broad analytics, profiling or disciplinary monitoring without safeguards can exceed what the DPDP framework permits.

GPS Tracking, Telematics and Surveillance Risk

A. Continuous Location Tracking

Modern fleet systems can record a vehicle’s location every few seconds, map routes, flag deviations and, in some cases, monitor movement beyond working hours. Under the DPDP Act, such continuous tracking must be clearly justified and limited to legitimate operational needs. Monitoring drivers during off-duty hours is particularly sensitive and may be difficult to defend. Retention periods must also be defined. “Always-on” tracking without transparency or necessity can easily be viewed as excessive surveillance.

B. Behavioural Analytics and Scoring

Telematics data is increasingly used to analyse driving patterns, rank performance and trigger warnings, penalties or even termination. Because these tools can directly impact livelihoods, they attract greater regulatory scrutiny. Companies must ensure that scoring systems are transparent, logically explainable and supported by grievance mechanisms. Opaque or automated decision-making without safeguards creates significant compliance risk under the DPDP framework.

Warehousing, CCTV and Biometrics

A. CCTV and Monitoring Systems

Warehouses commonly rely on CCTV systems to prevent theft and monitor workplace safety. While these are legitimate objectives, the use of surveillance must be transparent and limited to clearly defined purposes. Employees should be informed about monitoring practices, and footage should be retained only for specified periods. Repurposing CCTV recordings for unrelated disciplinary reviews or productivity analysis, without prior disclosure, may breach DPDP principles of purpose limitation and fairness.

B. Biometric Attendance Systems

Fingerprint and facial recognition systems are increasingly used for attendance and access control. However, biometric data is permanent and highly sensitive—once compromised, it cannot be changed like a password. Because of this heightened risk, its use must be strictly necessary and proportionate. Organisations should assess whether less intrusive alternatives are available before deploying biometric systems.

Multi-Party Data Sharing Across the Supply Chain

A. Shippers, Platforms and Intermediaries

Logistics operations depend on constant data exchange between shippers, e-commerce platforms, transporters, subcontractors and last-mile partners. However, personal data cannot simply travel “with the shipment.” Each transfer must be tied to a defined purpose, with clear allocation of roles whether a party acts as a data fiduciary or processor and supported by appropriate contractual safeguards. Unstructured or informal sharing creates significant compliance risk under the DPDP Act.

B. Proof of Delivery and Customer Data Leakage

Proof-of-delivery records often include photographs, signatures and contact details. Sharing or retaining this information beyond what is operationally required can expose customers to privacy and security risks especially where images reveal homes, family members or surrounding premises. Minimisation and controlled access are essential to prevent unnecessary data leakage.

Cross-Border Supply Chains and Data Transfers

A. Global Logistics Networks

International logistics involves:

  • Overseas tracking platforms
  • Global TMS and WMS providers
  • Cross-border customer support teams

Under the DPDP Act, cross-border transfers are permitted only to government-notified jurisdictions.

B. Operational Risk

Logistics companies must:

  • Map cross-border data flows
  • Monitor notifications
  • Plan localisation or restricted-access architectures

Ignoring transfer rules can disrupt real-time operations and contractual commitments.

Data Breaches: Physical and Digital Harm

A. Breach Scenarios

Data breaches in the logistics sector can expose sensitive operational and personal information, including delivery routes, historical driver location data, and customer addresses or phone numbers. Unlike many other industries, such disclosures carry a direct physical risk. Misused data can facilitate theft, cargo hijacking, stalking or harassment, making the consequences both digital and real-world.

B. Mandatory Notification

The DPDP Act and Rules require organisations to notify the Data Protection Board of India and affected individuals in the event of a personal data breach. In logistics operations, where compromised data may endanger physical safety, regulators may treat enforcement more seriously. Timely reporting and demonstrable mitigation efforts are therefore critical.

Penalties, Enforcement and Commercial Consequences

The DPDP Act permits penalties of up to INR 250 crore per contravention, with enforcement calibrated to factors such as the nature of the data involved (including location or biometric data), the scale and duration of processing, and mitigation measures adopted. For logistics companies engaged in continuous tracking or workforce monitoring, exposure may be heightened. Beyond financial penalties, non-compliance can trigger loss of enterprise contracts, labour disputes, platform de-listing and reputational damage making strong data governance an emerging commercial necessity rather than a mere regulatory formality.

Compliance Roadmap for Logistics and Supply Chain Businesses

  • Comprehensive Data Flow Assessment: Map and document all streams of location, employee and customer data across systems and partners.
  • Surveillance Rationalisation: Evaluate GPS, CCTV and analytics tools to ensure they are strictly necessary and clearly define limits, including off-duty tracking boundaries.
  • Enhanced Transparency Measures: Issue clear, accessible privacy disclosures to drivers, warehouse staff and customers explaining how their data is used.
  • Strengthened Third-Party Controls: Revise vendor and subcontractor agreements to restrict secondary use of data and implement periodic compliance audits.
  • Cross-Border Data Management: Review international data transfers, segment sensitive datasets where required and monitor regulatory notifications affecting overseas processing.

Conclusion: Moving Goods Without Over-Monitoring People

India’s data protection framework does not seek to slow down logistics operations but it seeks to discipline how personal data is used within them. Tracking, analytics and automation remain legitimate tools, but they must be structured around fairness, proportionality and transparency.

Supply-chain businesses that embed privacy safeguards into system design and vendor governance will reduce regulatory exposure while strengthening workforce confidence and client trust. In an industry built on reliability, responsible data practices are fast becoming part of operational excellence itself.