Measurement

Traveller tracking: the 2 gaps and what the ICO requires

Every travel management company will show you a map with dots on it. The demonstration is genuinely impressive and the tool is genuinely useful, and there is a structural limitation nobody mentions during it: the map shows what the system booked.

Travel booked on a personal card, on an airline’s own website, by an assistant who has always done it that way, or through a conference organiser’s block booking, is not a faint dot. It is no dot. The map is complete, confident and wrong, and nothing on the screen indicates which.

Why this is worse than an obvious gap

An incomplete report that announces its own incompleteness is a manageable problem. You know to ask elsewhere.

A traveller-tracking report does not do that. It answers the question “who is in Jakarta” with a list, and the list looks like the answer. The failure mode is not that somebody is missed — it is that somebody is missed and the report said otherwise, which is a much harder thing to catch and a much worse thing to explain afterwards.

The duty this sits under is s.2(1) of the Health and Safety at Work etc. Act 1974, and the duty is the employer’s. A tool does not discharge it; it helps you discharge it, and only over the population it can see.

Measuring it, before buying anything

This takes an afternoon and no procurement:

1. Take a quarter. One complete quarter, far enough back that expenses have settled.
2. Pull travel spend from the booking channel. Whatever your current supplier or tool reports: air, rail, hotel, for that quarter.
3. Pull travel spend from everywhere else. Corporate card transactions in travel merchant categories, plus travel lines in expense claims, for the same quarter.
4. Subtract. The second number, minus anything that is genuinely also in the first, is your leakage.
5. Do it by department. The total is a number. The breakdown is a plan, because leakage is almost never evenly distributed — it concentrates in one team, one office, or one senior traveller’s assistant.

Expect the result to be larger than anyone predicted. That is the normal outcome, not a sign that the method is wrong.

What the number actually tells you

A large, concentrated figure is good news. Concentrated leakage is a conversation with a small number of people, and it is fixable without a system change.

A large, evenly spread figure is a policy problem. If everyone is booking around the channel, the channel is either difficult, slow, or does not have the content people need. Those are three different fixes and none of them is a better tracking product.

A small figure changes what you should be buying. If leakage is genuinely minimal, tracking capability is worth paying for, because it will actually see what you need it to see.

Two questions for a supplier, sharper than the usual one

Instead of do you offer traveller tracking — to which the answer is always yes — the two questions that separate suppliers are:

• “What happens to travel booked outside the channel? Can any of it be brought in after the fact, and how?” Some suppliers can ingest itineraries from other sources, which does not solve leakage but does put the dot on the map.
• “Show us, live, who is in a named city on a named date, using a test itinerary.” Not a screenshot, not a case study. A demonstration takes five minutes and ends several arguments.

Both are in section 6 of the free tender template on this site, alongside the rest of the duty-of-care questions.

The second gap: switching tracking on is monitoring workers

The first gap is technical — the system cannot see what it did not book. The second is legal, and it runs the other way: everything the system can see is personal information about employees, collected continuously.

The ICO’s definition is deliberately wide:

any form of monitoring of people who carry out work on your behalf. This can include monitoring workers on particular work premises or elsewhere

“Or elsewhere” is the phrase that puts a travel programme inside it. Knowing which of your staff is in which city on which night is monitoring, and it does not stop being monitoring because the purpose is their safety.

What that requires, in the ICO’s own words

Three obligations, and the ICO states all three as must:

you must do this monitoring in a way that is lawful and fair to workers

You must carry out a DPIA before undertaking any processing likely to cause high risk to workers’ and other people’s interests

Apart from in very exceptional circumstances where covert monitoring is justified, you must inform workers about any monitoring

And on making people aware of the detail rather than the fact:

You must make sure workers are aware of how and what personal information you are collecting during any monitoring

The four together, against what a travel programme actually has to produce:

Why legitimate interests is the wrong default here

Most organisations reach for legitimate interests because consent from an employee is fragile. The ICO’s own caveat is the one to read before doing that:

Legitimate interests may not be the most appropriate lawful basis if: you are monitoring in ways workers do not understand and would not reasonably expect

Duty of care is a strong purpose and travellers generally do expect their employer to know where they are on a work trip. That is a reasonable position — but it is a position you have to have reached deliberately and written down, not one you can assume from the fact that the purpose is benign. The test in the guidance is what workers understand and reasonably expect, which is a question about what you told them.

The practical consequence for a tender

Two things belong in the supplier questions, and neither is usually there:

• What personal data does the tracking product hold, where is it processed, and for how long? You cannot write a retention line into your own policy without this.
• What will the supplier give you towards a DPIA? The assessment is yours to make; a supplier that has done it for other clients can hand you the processing description rather than leaving you to reconstruct it.

Both sit alongside the duty-of-care questions in section 6 of the free RFP and ITT template, and the employer duty they exist to discharge is set out on duty of care to business travellers.

The two obligations point the same way

It is worth noticing that the health-and-safety duty and the data-protection duty do not conflict here — they both push towards the same act. Section 2(2)(c) of the Health and Safety at Work etc. Act 1974 requires information and instruction; the ICO requires that workers be informed about monitoring. Telling your travellers what is tracked, why, and who can see it satisfies part of both at once. It is one paragraph in a travel policy and it is the cheapest compliance work available in this area.

The uncomfortable conclusion

If you have meaningful leakage, buying a better tracking system is buying a better view of a subset. The money is better spent on making the channel the path of least resistance — content people actually want, a tool that is faster than the alternative, and a policy that says what happens when somebody books around it.

That is a less satisfying answer than a product, and it is cheaper.

Two gaps, then. One is that the map is incomplete and does not say so; the fix for that is the booking channel, not a better product. The other is that everything on the map is employee personal data, and the fix for that is a lawful basis, a DPIA where the risk is high, and a paragraph that tells people what you are doing. Neither gap is closed by procurement, which is why both are worth settling before the demonstration rather than after.

More on choosing between suppliers on the eleven comparison criteria.

All notes · Comparison criteria · RFP template