More home care providers want to see where their carers are during a visit — to confirm care is delivered, to respond faster when something is wrong, and to protect staff who work alone. In the UK that is allowed, but only when it is necessary, proportionate and open. This guide explains what the law expects, where providers go wrong, and what a fair set-up looks like. See how Carelo Live Tracking works.
Domiciliary care happens in other people's homes, often by one carer working alone. Providers want location data for three honest reasons:
None of these needs to know where a carer is on their lunch break, on the school run or at home in the evening. That single observation shapes everything below.
A carer's location is personal data, so UK GDPR and the Data Protection Act 2018 apply. The ICO's guidance on monitoring workers sets the tone: monitoring must be necessary for a clear purpose, proportionate to that purpose, and transparent — workers must know it is happening, why, and what is recorded. Covert monitoring of staff is very rarely justified.
In practice that means three questions a provider should be able to answer in writing: what problem does tracking solve, why is a less intrusive option not enough, and how are carers told.
Many providers assume they need each carer's consent. Under UK GDPR, consent from an employee is rarely valid, because of the imbalance of power — a carer may not feel free to say no to their employer. Most providers rely instead on legitimate interests: safe, verified care visits. That requires a short balancing test showing the interest is real, the tracking is necessary for it, and it does not override the carer's rights.
Carers should still be told clearly and asked to acknowledge it — but that acknowledgement is how you meet transparency, not your legal basis.
Systematic monitoring of workers' location is the kind of processing the ICO expects a data protection impact assessment (DPIA) for. A DPIA records the purpose, the data collected, who sees it, how long it is kept, the risks to carers and how they are reduced. It is a working document, reviewed when anything changes.
Alongside it, a short monitoring policy tells staff in plain words what is tracked, when, why, who can see it and how to raise a concern. Both should exist before tracking is switched on, not after a complaint.
The strongest single safeguard is to limit tracking to the time a carer is actually delivering care: from check-in to check-out of a visit. Outside visits — travelling between calls, breaks, off-duty time — there is no visit to verify and the case for tracking falls away. All-day tracking of a care worker's phone is very difficult to justify.
Other limits that keep tracking proportionate: positions every few minutes rather than every second, alerts only for things that need a person, access limited to the office team who need it, and records kept no longer than the purpose requires.
Transparency is not a line buried in a contract. Good practice is a clear notice in the app before the first tracked visit — what is shared, when it starts and stops, and with whom — which the carer acknowledges once. The phone itself should also show when location is in use. Repeating a warning on every visit adds nothing and quickly becomes noise; once, clearly, is the standard.
Carelo's Live Tracking add-on was built around these rules. It runs only between a carer's check-in and check-out of a visit — before, between and after visits the app shares nothing. It cannot be switched on until an owner or manager has signed a monitoring policy and DPIA, both pre-filled templates. Each carer sees a clear one-time notice in the Carelo app and agrees once, and the phone shows its own location indicator during tracked visits. Only the provider's office team can see positions, and there are just two alerts: a carer outside the client's home zone for longer than the company's setting, and a phone that has stopped reporting.
Electronic call monitoring — GPS check-in and check-out, late and missed calls — is included in every Carelo plan. Live Tracking is optional, from £19 a month.
Usually you should not rely on consent, because an employee's consent is rarely freely given. Most providers rely on legitimate interests, supported by a DPIA, and make sure carers are clearly told. Take advice for your own circumstances.
It is very hard to justify. There is no visit to verify while a carer is travelling or on a break, so tracking should be limited to the time between check-in and check-out.
Systematic monitoring of workers' location is the kind of processing the ICO expects a DPIA for. Write it before you switch tracking on and review it when anything changes.
They should not. Location data is for the provider's office to verify visits and support staff. Families can see visits, notes and updates without seeing a carer's position.
No. This guide explains the general position for UK home care providers. Your company is the data controller; take advice from your own data protection adviser for your circumstances.