Yes, companies should track employee location during business travel, and in many jurisdictions, they have a legal obligation to do so. Tracking is not about surveillance; it is a core component of duty of care, enabling organisations to locate, communicate with, and assist employees when something goes wrong abroad. The sections below address the most common questions around business traveller tracking, from legal obligations to policy design.
What are the legal obligations companies have to track travelling employees?
Companies have a legal duty of care to take reasonable steps to protect employees while they travel for work. In practice, this means knowing where employees are, being able to reach them during an incident, and having a plan to assist them. Failing to meet this standard can expose organisations to legal liability, regulatory scrutiny, and reputational damage.
The specific legal framework varies by country, but the underlying principle is consistent across most jurisdictions. In the UK, the Health and Safety at Work Act 1974 requires employers to ensure the health, safety, and welfare of employees as far as reasonably practicable, and this obligation extends to overseas travel. In the US, OSHA standards and common law negligence principles apply similar expectations. The EU’s General Data Protection Regulation (GDPR) also shapes how tracking must be implemented, requiring transparency, proportionality, and a lawful basis for processing location data.
ISO 31030, the international standard for travel risk management, provides a widely recognised framework for how organisations should structure their duty of care obligations. It covers pre-travel risk assessment, real-time monitoring, and post-travel support. Aligning with ISO 31030 demonstrates that an organisation is taking a structured, defensible approach to employee travel safety rather than acting reactively.
The key legal takeaway is this: organisations do not necessarily need to track every movement in granular detail, but they must be able to demonstrate that they took reasonable steps to know where their employees were and to respond effectively if something went wrong.
What types of employee location tracking are used during business travel?
Employee location tracking during business travel takes several forms, ranging from manual check-in systems to sophisticated real-time platforms. The right approach depends on the risk level of the destination, the size of the travelling workforce, and the organisation’s existing infrastructure.
Itinerary-based tracking
The most basic form of travel tracking involves collecting and monitoring employee itineraries before and during travel. Travel managers or HR teams maintain a record of flight details, hotel bookings, and planned movements. This allows the organisation to know where an employee should be at any given time, even without real-time GPS data. It is a low-friction approach suited to lower-risk destinations where the primary concern is knowing who is travelling rather than monitoring their precise location.
Real-time GPS and app-based tracking
Corporate travel safety apps and travel risk management platforms enable real-time location sharing via employees’ mobile devices. These tools allow travel risk managers to see where employees are on a live map, send targeted alerts to individuals in affected areas, and initiate contact immediately during an incident. Many platforms also allow employees to check in manually or trigger an SOS alert if they feel at risk. This approach is particularly valuable in medium- to high-risk environments where conditions can change rapidly.
Integrated tracking ecosystems
More advanced organisations use integrated technology ecosystems that combine GPS tracking, communication tools, and intelligence feeds in a single platform. These systems link traveller location data with live threat intelligence, enabling automated alerts when a tracked employee is in proximity to a developing incident. NGS, for example, operates the Aurora platform alongside SIREN for mass emergency communication, giving travel risk managers a consolidated view of personnel location and threat status simultaneously.
How does employee location tracking support emergency response?
Employee location tracking dramatically improves emergency response by eliminating the most critical delay in any crisis: finding out where people are. When an incident occurs, whether a natural disaster, civil unrest, a medical emergency, or a security threat, response teams need to know immediately which employees are affected, where they are, and how to reach them. Tracking removes the guesswork and compresses response timelines.
Without location data, organisations face a reactive scramble. They rely on employees to make contact, which assumes the employee is safe, has connectivity, and knows to report in. In a genuine emergency, none of those assumptions hold reliably. Real-time tracking inverts this: the organisation already knows where the employee is and can initiate contact and assistance without waiting to hear from them.
The operational value of tracking extends beyond the initial response. During an evacuation or crisis, conditions change quickly. Routes close, borders shift, and transport options disappear. A travel risk manager with live visibility of employee locations can adjust plans dynamically, redirect personnel, and coordinate with ground teams in real time. NGS has demonstrated this capability across multiple high-stakes operations, including evacuations during the Middle East crisis where tracking enabled coordinated movement of hundreds of individuals and families across several countries simultaneously, with zero incidents during transit.
For organisations operating in high-risk environments, the difference between a 40-minute response and a multi-day delay can determine outcomes. Location tracking is the foundational capability that makes rapid response possible.
What’s the difference between traveller tracking and employee surveillance?
Traveller tracking and employee surveillance are fundamentally different in purpose, scope, and legal basis. Traveller tracking is a duty of care measure applied during business travel to protect employees in unfamiliar or potentially dangerous environments. Employee surveillance is the ongoing monitoring of employee behaviour, productivity, or communications, typically in a domestic workplace context, and carries very different ethical and legal implications.
The distinction matters for several reasons. First, purpose determines legality. Under GDPR and equivalent data protection frameworks, processing employee location data is permissible when there is a legitimate purpose and the processing is proportionate. Protecting an employee’s physical safety during international travel meets this standard. Monitoring an employee’s movements in their home city to assess productivity does not.
Second, scope defines the boundary. Legitimate business traveller tracking is limited to the duration of the trip and the locations relevant to the travel itinerary. It does not extend to personal time, personal devices, or activities unrelated to the business purpose of the trip. Employees should know exactly what is being tracked, when tracking begins and ends, and how the data is used and stored.
Third, consent and transparency are essential. Effective travel tracking programmes communicate clearly with employees about what data is collected and why. When employees understand that tracking exists to help them, not to monitor their performance, acceptance and compliance are significantly higher. The framing matters: this is a safety tool, not a management tool.
Organisations that conflate the two risk damaging employee trust, creating legal exposure, and undermining the very duty of care programme they are trying to build.
When should companies require employee location sharing during travel?
Companies should require employee location sharing whenever the risk profile of a trip justifies it, which, in practice, means any international business travel to medium- or high-risk destinations, and any travel where the employee will be operating without a fixed base or regular contact points. The threshold should be defined in policy, not left to individual manager discretion.
For low-risk destinations with stable political and security environments, a lighter approach may be appropriate: itinerary submission, hotel registration, and a local emergency contact number may be sufficient. As destination risk increases, the requirement for real-time location sharing should increase proportionally.
Several specific circumstances should trigger mandatory location sharing regardless of destination risk level:
- Travel to destinations with active travel advisories or elevated threat ratings
- Solo travel, particularly to unfamiliar regions or areas with limited infrastructure
- Travel involving remote locations, long road journeys, or limited mobile connectivity
- Visits to high-profile sites, government facilities, or locations with known security concerns
- Any travel that coincides with a developing geopolitical, civil, or environmental incident
- Executives or high-profile individuals who may represent a targeted risk
The underlying principle is proportionality. The level of monitoring should match the level of risk. A pre-travel risk briefing, which should be standard practice for all international travel, will typically surface the factors that determine where on that spectrum a given trip sits.
What should a company’s employee travel tracking policy include?
A company’s employee travel tracking policy should define the scope of tracking, the legal basis for data collection, the tools used, employee rights and responsibilities, and the escalation procedures that activate when a tracked employee cannot be reached or is in a known risk area. A policy without these elements is incomplete and unlikely to hold up under scrutiny.
The core components of a robust travel tracking policy are:
- Scope and applicability: Define which employees and which types of travel are covered. This includes geographic scope, trip duration thresholds, and any role-specific requirements.
- Data collection and retention: Specify what location data is collected, how it is stored, who can access it, and how long it is retained after a trip concludes. This is essential for GDPR and equivalent compliance.
- Technology requirements: Identify the approved travel risk management platform or corporate travel safety app, and set out the requirement for employees to have it active during covered travel.
- Employee responsibilities: Clarify what employees must do before, during, and after travel, including itinerary submission, check-in requirements, and how to raise a concern or trigger an emergency alert.
- Response protocols: Define what happens when an employee cannot be reached, when a travel risk alert is issued for a destination, or when an employee activates an SOS. Who is notified, what actions are taken, and within what timeframe?
- Pre-travel risk briefing process: Embed the requirement for destination-specific risk briefings as part of the travel approval process, not an optional add-on.
- Policy review cycle: Set a regular review cadence to ensure the policy reflects current threat environments, legal developments, and changes to the organisation’s travel footprint.
A policy aligned with ISO 31030 provides a defensible, internationally recognised framework for all of the above. It also signals to employees, insurers, and regulators that the organisation is taking its duty of care obligations seriously rather than treating travel risk as an afterthought.
How NGS helps with employee travel tracking and duty of care
Northcott Global Solutions provides organisations with the operational infrastructure to meet their duty of care obligations across every stage of business travel. Whether you are building a travel risk policy from scratch or strengthening an existing programme, NGS delivers the tools, expertise, and 24/7 support to keep employees safe and your organisation protected.
- Aurora platform: Real-time traveller tracking, country and regional risk assessments, and itinerary monitoring in a single web-based system
- SIREN: Mass emergency communication that reaches all travellers in an affected area instantly, without manual intervention
- 24/7 UK Operations Centre: Round-the-clock monitoring with an average urban response time of 40 minutes or less
- Pre-travel risk briefings: Destination-specific guidance calibrated to low-, medium-, and high-risk environments
- Emergency response and evacuation: Medical, security, and crisis response support available anywhere in the world
- ISO 31030 alignment: All services structured to support organisations in meeting the international standard for travel risk management
If your organisation needs a stronger, more structured approach to business traveller tracking and duty of care, speak to the NGS team to discuss how we can support your travel risk programme.
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