GPS check-in for cleaners and the NZ Privacy Act 2020

This article is general information for New Zealand cleaning business owners, not legal advice. Rules change, so check the official sources linked below or talk to an employment lawyer or adviser about your situation.

GPS check-in apps are an easy way to know your cleaners arrived at the right site. They also raise a fair question from staff: "Are you tracking me?" In New Zealand the Privacy Act 2020 applies to location data about employees, so it's worth getting this right from the start. This guide explains the key points and a proportionate way to use location for a cleaning team.

Is location data personal information?

Yes, when it can be linked to a person. The Office of the Privacy Commissioner says GPS data about work vehicles can be personal information about employees. A check-in on a cleaner's phone that records who checked in, where and when is clearly personal information. That means the Privacy Act's information privacy principles apply to how you collect, use, store and share it.

What the Privacy Commissioner says employers can collect

The Privacy Commissioner's guidance on what employers can collect makes several points that apply directly:

• Employers can only collect information they need to carry out their legitimate functions, and must be able to justify why it's needed. They can't collect it "just because they can".
• Employers should be open with staff about what's collected and what it will be used for, for example in workplace policies or the employment agreement.
• Information must not be collected in ways that are unreasonably intrusive.

On GPS in vehicles specifically, the Commissioner suggests clear policies, making sure workers know the GPS exists and what the policies are, and handling any information about non-work time very differently from information gathered on the job.

Applying that to cleaners

What does a cleaning company actually need to know? Usually:

1. that the cleaner arrived at the right site
2. what time they started
3. what time they finished.

A location point at check-in and another at check-out answers all three. Continuous tracking during the shift, or worse after it, collects far more than that purpose needs. It's harder to justify as necessary and more likely to be seen as intrusive. It also tends to damage trust with the very people you rely on every night.

That's the basis of a proportionate approach: location only at the moments it's needed, for a purpose you've explained.

A practical approach for cleaning companies

1. Decide and write down the purpose

For example: "We record location when you check in and out of a client site, to confirm attendance for clients and to create accurate time records for pay." Keep the purpose narrow, and don't quietly expand it later.

2. Collect only at check-in and check-out

Choose tools that let you record location at those moments only. Avoid background tracking unless you have a specific, justified reason and have consulted staff.

3. Tell cleaners up front

Before anyone uses the app, explain what's recorded, why, who can see it, how long it's kept and how they can ask to see their own information. Put it in your workplace policy too. Employment New Zealand suggests that employers considering monitoring develop a policy explaining why and when it will happen, consult with employees (and unions if applicable) and make sure staff know about it.

4. Limit who can see it

Owners and managers who need it for rosters, client proof or payroll. Not every supervisor and not clients, unless you've told staff that clients will see check-in times.

5. Keep it only as long as needed

Check-in and check-out times form part of your time records, which you need to keep for 6 years under employment law (see our guide to cleaner timesheets and NZ record keeping). Decide what else you keep, such as exact coordinates or photos, and for how long. Don't keep things forever "just in case".

6. Use it for what you said

If you told staff location is for attendance and pay, don't start using it to monitor personal errands. If you might use records in a disciplinary process, say so in your policy.

7. Let staff see their own information

Under the Privacy Act, people can ask for access to information about themselves and ask for it to be corrected. Make it easy.

What about photos?

Before and after photos are about the work, but photos can capture people, screens or documents by accident. Tell cleaners to photograph empty spaces only, and to avoid anything that shows personal or client information. This keeps photos useful as evidence and avoids collecting information you don't need.

Cleaners' own phones

Many cleaners use their own phones for work apps. That makes it even more important that the app records location only when the cleaner actively checks in or out, and not in the background. Explain this clearly. Cleaners are often relieved to hear that location is only recorded at those two moments.

Sample wording for a notice

Adapt this to your business:

Summary

• Location data about cleaners is personal information under the Privacy Act 2020.
• Collect only what you need for a clear purpose. For cleaning, check-in and check-out is usually enough.
• Be open with staff and put it in a policy. Consult before you start.
• Limit access, keep it only as long as needed, and use it only for what you said.

Sources

• Office of the Privacy Commissioner: What information is my employer entitled to collect while I'm working?
• Office of the Privacy Commissioner: Is my employer allowed to use GPS in work vehicles?
• Employment New Zealand: Employee privacy

Sources checked 15 November 2026.