GPS Features in Sergio

Compliance Guide for Employers

Version 3.0 | Last Updated: December 3, 2025

IMPORTANT LEGAL DISCLAIMER: This guide is for informational purposes only and does NOT constitute legal advice. Employment and privacy laws vary significantly by jurisdiction. You must consult with an employment attorney licensed in your jurisdiction(s) before enabling any employee monitoring or GPS tracking features.

Sergio is a B2B software provider, not an employer. You are the employer. Compliance with employment laws is YOUR responsibility.

What Sergio Provides

Turn-by-Turn Navigation

GPS navigation for technicians to find customer addresses
Processed locally on the technician's device
No tracking or surveillance - just routing
Similar to using Google Maps or Waze

Geofencing for Job Completion

Automatic detection when technician arrives at job site (within 50 meters)
Used for automatic job status updates
Helps with customer arrival notifications
Not continuous tracking - just periodic location checks

Real-Time Location Tracking (Optional)

See where technicians are during active navigation
GPS coordinates sent every 5 minutes (not continuous surveillance)
Location data transmitted for display, not stored in database
Device cache deleted automatically after 24 hours
Requires dual consent: admin enables + technician grants iOS permission

Your Responsibility as an Employer

1. Check Your Local Employment Laws

Employment laws vary by location. Some jurisdictions require:

Written consent from employees
Advance notice before implementing monitoring
Specific language in employment contracts
Union consultation (if applicable)

Canadian Requirements by Province

Federal (PIPEDA)

Applies to federally regulated employers and cross-border data
Requires consent for collection of personal information
Must identify purposes at or before collection

Ontario - MANDATORY (Working for Workers Act, 2022)

If you have 25 or more employees in Ontario, you are legally required to have a written electronic monitoring policy that includes:

Whether you electronically monitor employees
Description of how and when monitoring occurs
Purposes for which information may be used
Date policy was prepared and any amendments

Timeline: Policy must be provided within 30 days of hire. Updated policy within 90 days of changes.

Quebec (Law 25) - Enhanced Requirements

Consent must be manifest, free, informed, and given for specific purposes
Privacy Impact Assessment may be required
Mandatory breach notification to CAI within 72 hours
Penalties: Up to $25 million CAD or 4% of worldwide turnover

British Columbia & Alberta (PIPA)

Consent required for collection, use, and disclosure
Must provide notice of purposes at or before collection
Employee may withdraw consent (subject to reasonable notice)

United States Requirements by State

State	Requirement
California	Written notice recommended. CCPA/CPRA provides privacy rights with employee exemptions.
New York	Written notice required (Civil Rights Law 52-c). Must post in conspicuous location AND provide at hire.
Connecticut	Written notice required (Gen. Stat. 31-48d). Must inform of monitoring types and usage.
Delaware	Written notice required for monitoring (Code 19-705).
Texas	No specific law, but tracking without consent may violate stalking laws. Written consent recommended.
Colorado	Colorado Privacy Act - written notice of data collection practices required.
Illinois	BIPA may apply if location creates identifiable "movement patterns." Private right of action.

2. Inform Your Technicians in Writing

What to tell them:

What data is collected (GPS coordinates, timestamps, job completion data)
When it's collected (during work hours? only during active jobs?)
Who can see it (dispatchers, managers)
How long it's kept (24 hours on device, 30 days metadata on server)
Why you're collecting it (route optimization, customer notifications, job verification)

How to tell them:

Add a section to your employee handbook
Include language in employment contracts
Send an email explaining the features
Hold a team meeting to discuss questions

3. Get Consent Where Required

Types of Consent

Informed Consent:

Employee understands what data is collected
Employee understands how it will be used
Employee understands who has access
Employee understands retention period

Valid Consent (Quebec Law 25 Standard):

Must be manifest (clear and unambiguous)
Must be free (not coerced)
Must be informed (full disclosure)
Must be specific (tied to particular purposes)
Must be revocable

4. Use Features Reasonably

Good reasons to use GPS:

Optimizing routes to save time and fuel
Providing accurate customer arrival notifications
Verifying job completion for billing
Responding to emergencies

Bad reasons to use GPS:

Micromanaging trustworthy employees
Tracking personal activities during off hours
Checking up on specific employees you don't like

What Data Does Sergio Collect?

Feature	What's Collected	Retention
Turn-by-Turn Navigation	GPS coordinates (device only), customer addresses for geocoding	24 hours (device cache)
Geofencing	Entry/exit timestamps at job sites, job completion data	24 hours device, 30 days metadata
Real-Time Location	GPS every 5 min during navigation, displayed only (not stored)	Not stored in database

NOT Collected: Location when navigation is off, 24/7 tracking, personal photos/messages, other apps, browsing history.

Technical Details (For Your Attorney)

Device cache: 24 hours maximum, then automatically deleted
Server metadata logs: 30 days (IP, timestamp, job ID only - no GPS coordinates)
Security: HTTPS encryption, Supabase Pro infrastructure (SOC 2, ISO 27001)
Data location: Canada (Montreal), United States (Mapbox geocoding only)
Sub-processors: Mapbox (geocoding), Supabase (database/backend)

Summary

Check local laws (or ask a lawyer)
Tell your employees what you're collecting and why
Get consent where required
Be reasonable - Don't misuse GPS data
Start small - Navigation first, add features gradually

We provide the technology. You're responsible for using it lawfully.