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DPIA template for firms using JobGate
Last updated 22 October 2026
A data protection impact assessment (DPIA) is a short record showing you've thought about the privacy risks of something before you start it. Because JobGate records workers' location at sign-in, many firms choose to do one, and the ICO expects it for workplace monitoring. This one is pre-filled for a typical building firm. Read it, change anything that's different for you, fill in the boxes, and keep a copy with your health and safety paperwork.
| Company | |
| Completed by / role | |
| Date | |
| Review by (suggest 12 months) |
1. What we're doing
We use JobGate for site sign-in. Everyone on our sites (our staff, subcontractors and visitors) scans a QR code on the site door with their phone to sign in and out, reads and signs the RAMS, COSHH and site rules, and answers a daily safety check. The office sees who's on site, timesheets, reports and permits, and gets a weekly copy of the records.
2. What data and whose
- People: our employees, subcontractors and their workers, visitors.
- Data: name, mobile number, company, job, sign-in and sign-out times, the phone's location once, at the moment of sign-in or sign-out, document signatures, daily check answers, reports and photos they choose to send, tickets they upload.
- Not collected: continuous tracking, location outside sign-in, contacts, or anything else from the phone.
- Special category data: none intended. Accident reports may mention injuries.
3. Why, and is it necessary?
| Purpose | Lawful basis | Why it's necessary and proportionate |
|---|---|---|
| Knowing who is on site (fire roll call, emergencies) | Legal obligation (health and safety law); legitimate interests | A live list is far more reliable than a paper sheet at the gate |
| Proving inductions and RAMS sign-off | Legal obligation; legitimate interests | We must show workers were informed of risks before starting |
| Accurate timesheets | Contract (paying people correctly); legitimate interests | Times are recorded only when people sign in and out |
| Location at sign-in | Legitimate interests | Taken once, only to show the sign-in happened on site. Sign-in still works if location is off; it's just flagged. Less intrusive than GPS trackers or fingerprint clocks |
Legitimate interests balance: workers expect to sign in on site; the data is limited to what's needed; there's no hidden or continuous monitoring; each person sees a privacy notice on their first sign-in; flags are prompts to check, not automatic discipline.
4. Risks and how they're handled
| Risk | Likelihood / impact | How it's reduced | Remaining risk |
|---|---|---|---|
| Location used to monitor people beyond site attendance | Low / medium | Location taken only at sign-in/out; no background tracking; our policy is that location flags are checked with the person before any action | Low |
| Wrong conclusion from bad location (poor signal, location off) | Medium / low | Flags are shown as "check", not proof; the worker can explain; office changes to hours are logged with reasons | Low |
| Unauthorised access to records | Low / medium | Office logins with roles; site managers only see their jobs; worker sign-in by text code or passkey; encrypted in transit; hosted by Cloudflare | Low |
| Records kept too long | Medium / low | We set a retention period (below) and delete old jobs | Low |
| Data transferred outside the UK | Medium / low | JobGate's providers are covered by UK-approved safeguards (see JobGate's data processing agreement) | Low |
| Workers not knowing what's recorded | Low / medium | Privacy notice shown on first sign-in; we also tell new starters at induction | Low |
5. Our decisions
| We keep site records for | e.g. 6 years after the job finishes |
| Location flags are handled by | e.g. speaking to the person first; no automatic action |
| Who can see records | e.g. directors, office manager, site managers for their own jobs |
| Who handles data requests |
6. Sign-off
| Remaining risk acceptable? | Yes / No |
| Approved by (name, role) | |
| Signature and date |
This template is a starting point, not legal advice. Change it to match how your firm actually works. If the remaining risk is high and you can't reduce it, the law requires you to consult the ICO before going ahead.