# Traveller tracking: what it is and when organisations need it Source: https://www.roamlytravel.com/guides/traveller-tracking-duty-of-care Publisher: Roamly Travel Last reviewed: 2026-10-30 Audience: Universities, Schools, Sports teams, Production crews, Event organisers, Corporate groups ## Short answer Traveller tracking means being able to find out where each member of a travelling group is and how to contact them, so you can respond quickly in an emergency. For most group trips this is met by an accurate manifest, itinerary, rooming list and check-in routine held by the leader and someone at home. Live location tracking by app or device is a further option that has to be necessary, proportionate and explained to the people being tracked, and it is not the same as the parent trackers that school guidance normally discourages. ## Key takeaways - Traveller tracking is one element of duty of care and appears as a risk treatment option in ISO 31030, which says treatments should be reasoned and proportionate to the risk exposure. - For most groups the baseline is a current manifest, itinerary, accommodation list and mobile numbers, held by the trip leader and a named person at home, plus headcounts and a check-in routine. - Live location tracking is justified more easily for remote, higher-risk or free-time-heavy trips, and needs a data protection assessment because the ICO expects monitoring to be necessary and proportionate. - The ICO says that if you can achieve your aim in a less intrusive way, you must do so, and that workers must be told about monitoring. - OEAP guidance says parents giving children their own electronic trackers should normally be discouraged, and the position can be set out in the code of conduct. ## What is traveller tracking? In duty of care terms, traveller tracking is knowing who is travelling, where they are and how to reach them, so that an organisation can account for everyone and respond when something happens. It is one of the practical components of duty of care described in our [duty of care guide](https://www.roamlytravel.com/guides/duty-of-care-group-travel). ISO 31030, the international guidance standard on travel risk management, lists traveller tracking among its risk treatment options alongside journey management, incident management planning and emergency contact points. Tracking is a spectrum, from a spreadsheet and a headcount to a phone app showing live locations. The right level depends on the group, the destination and what you would do with the information. ## What are the levels of tracking for a group? | Level | What it involves | Typically enough for | | --- | --- | --- | | 1. Know the plan | Manifest with passport names and nationalities, mobile numbers, flights, accommodation and rooming list, daily itinerary, shared with the home contact before departure. | Most supervised school, university, team and event trips in low-risk destinations. | | 2. Check in routinely | Headcounts at every transition, buddy pairs, set meeting points and times for free time, a daily check-in message to the home contact. | Groups with free time or older students in cities. | | 3. Share location | Location sharing by app, device or tracker, switched on for set periods or tasks, with the purpose and limits explained. | Remote fieldwork, lone working, higher-risk destinations, or when a risk assessment shows the lower levels are not enough. | Nobody should skip level 1. The home contact can only act if they hold the same manifest and itinerary as the leader. See the trip leader pack and [rooming list](https://www.roamlytravel.com/guides/rooming-list-how-to) guides. ## Do organisations have to track travellers? The sources reviewed for this article do not make live location tracking a legal requirement for group trips. The duty is the broader one of taking reasonable care against foreseeable harm, which the [duty of care guide](https://www.roamlytravel.com/guides/duty-of-care-group-travel) explains. Tracking is a way of meeting that duty, not a legal box to tick. ISO 31030 is voluntary guidance, and its introduction says that although it offers a full set of treatment options, application should be reasoned and proportionate to the risk exposure. A practical test: if an incident happened tonight, could you find out within minutes who is where? If not, add the missing level. This is general information, not legal advice, so confirm your position with your own advisers. ## When is live location tracking justified? - **Remote or hard-to-reach locations,** where help takes time to arrive and a delay in finding someone has serious consequences. See safe fieldwork in remote locations. - **Lone working,** where one person is deliberately away from the group. See lone working for researchers abroad. - **Higher-risk destinations,** where the risk assessment identifies threats such as civil unrest or crime that make fast location of travellers valuable. - **Older participants with real independence,** such as adult students on placement, where headcounts are not practical. Live tracking is a poorer fit for children who are with a leader all day. There headcounts are the control, and a tracking system adds data you must protect without much safety gain. ## What are the data protection limits on tracking? Location data is personal data. The Information Commissioner's Office (ICO) guidance on monitoring workers says monitoring must be necessary and proportionate, that you must inform people about monitoring, and that you should complete a data protection impact assessment (DPIA) for monitoring likely to create a high risk to people's rights. On device monitoring, it says that if you can achieve your aim in a less intrusive way, you must do so. - **Define the purpose:** safety in an emergency, not general performance monitoring. - **Limit when it is on:** for example, only during travel days or defined activities, or let people switch it off outside those periods. - **Tell participants and, for under-18s, parents,** what is collected, who sees it, how long it is kept and when it is switched on. - **Restrict access and set deletion:** only the leader and home contact see it, and it is deleted after the trip. For the wider topic, see our guide to handling traveller data under UK GDPR. Ask your data protection officer before choosing a tool. > **Emergencies are different** > The ICO says that in an emergency you should go ahead and share data as is necessary and proportionate, and that data protection law does not prevent sharing where it is appropriate. Plan ahead which details you would share with emergency services, and document what you shared if you could not record it at the time. ## What about parents tracking their own children? OEAP National Guidance on informing parents says that when parents consider giving a child an electronic tracker or tracking phone app, this should normally be discouraged. It lists three concerns: mistrust between parents and leaders and tension between parents who do and do not use trackers, safeguarding risks if an unauthorised person can track a child, and a reduction in the child's real or perceived independence. It suggests covering trackers in policy or the code of conduct, as is done for mobile phones. ## How Roamly can help Roamly's [logistics service](https://www.roamlytravel.com/services/logistics) produces the itineraries, manifests and supplier contact lists that traveller tracking depends on, and its [consulting](https://www.roamlytravel.com/services/consulting) service helps organisations decide what level of tracking suits a trip. Use the free [travel risk assessment tool](https://www.roamlytravel.com/travel-risk-assessment) to record your decision, or [contact us](https://www.roamlytravel.com/contact). ## Frequently asked questions ### What is the difference between traveller tracking and travel tracking apps? Traveller tracking is the duty of care activity of knowing where your people are and how to reach them. A travel tracking app is one tool for doing it. A manifest, itinerary and regular check-ins can meet the need without an app. ### Can we require students to share their location? This needs care. The ICO expects monitoring to be necessary and proportionate and expects people to be told about it. Whether a requirement is justified depends on the trip and your lawful basis, so take advice from your data protection officer and consider whether a less intrusive control would meet the aim. ### Do we need a DPIA to use a location tracking tool? The ICO says to complete a DPIA for monitoring likely to create a high risk to people's rights. Whether tracking meets that bar depends on the use, but undertaking and recording an assessment is the safer course. Your data protection officer can advise. ### Should school staff use a tracking app on pupils? Most supervised school trips rely on headcounts, buddy systems and meeting points. A tracking app adds data protection duties and is not necessary in most cases. If your employer's policy or risk assessment calls for one, explain it to parents in advance. ### Who should hold the tracking information at home? The named home contact, who needs to be reachable for the whole trip, should hold the manifest, itinerary and any location access, with a backup person so that cover is continuous. ## Sources - [ISO 31030:2021 Travel risk management - Guidance for organizations (preview and scope)](https://www.iso.org/standard/54204.html) - [ICO: Monitoring workers](https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/employment/monitoring-workers/) - [ICO: Specific data protection considerations for different methods of monitoring workers](https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/employment/monitoring-workers/specific-data-protection-considerations-for-different-ways-or-methods-of-monitoring-workers/) - [ICO: Data sharing in an urgent situation or in an emergency](https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/data-sharing/data-sharing-a-code-of-practice/data-sharing-in-an-urgent-situation-or-in-an-emergency/) - [OEAP National Guidance 4.3d Parental Consent and Informing Parents](https://oeapng.info/download/1264/)