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Time tracking and data protection

Working time data says when each person arrives, when they rest and when they are off sick. It is ordinary personal data, handled badly it becomes a problem, and most of what you need to do is decided once at the start.

This is not legal advice. A summary of UK GDPR and of the record-keeping rules, checked on 23 September 2026. Not advice on your situation.

The four decisions to make once

  1. Lawful basis. Legal obligation covers the records the law requires. Rotas, balances and job costing usually sit on legitimate interests or contract. Write down which is which — you will be asked.
  2. Retention. Two years under regulation 9(1)(b) for working time; six years for minimum wage records under regulation 59(8). Pick the longer one that applies and delete after it.
  3. Who sees what. Four roles out of the box — employee, supervisor, employee representative, administrator — rather than one login that everyone shares, which is how most small firms actually lose control of this.
  4. Transparency. Tell people before you start. What to tell them.

Special category data, and how to avoid needing it

Two things in a time system can turn into special category data. Biometrics used to recognise someone fall under Article 9 whether you identify or merely verify — so we do not offer them. Sickness is health data, so absence is recorded as absence without a reason or diagnosis attached, and the AI assistant never touches it.

Where the data is

  • Servers in Germany under GDPR, encrypted in transit, backed up daily — or your own server, where nothing reaches us at all.
  • Every customer has their own installation and their own database. No shared database means the failure mode where one company sees another’s data does not exist.
  • Full export in open formats, at any time, including after you stop being a customer. Your records are yours.

Of the fifteen vendors we compared, five say which country holds the data. The table.

Rights, and how long each one takes

  • Access: one button, one file.
  • Rectification: correction requests are built in, with the original kept beside the change.
  • Erasure: after the retention period, controlled deletion rather than a database left to grow forever.
  • Portability: open formats, always.

Questions we get

How long can we keep working time records?

Long enough for the purpose, and no longer. The Working Time Regulations set two years (regulation 9(1)(b)); minimum wage records must be kept six years (regulation 59(8) of the NMW Regulations 2015). Keeping everything forever is not a neutral choice — it is a decision you would have to justify.

What is our lawful basis?

Usually legal obligation for the record-keeping itself, and legitimate interests or contract for the operational parts such as rotas. Consent is a poor fit at work because of the imbalance of power, and it is not available at all for biometric data.

Who is the controller?

You are. When we host, we are your processor and act on your instructions under a data processing agreement. On your own server there is no processor at all, because the data never reaches us.

What about a subject access request?

Everything held about one person exports with one button, in a readable file. That is the whole point of building it in: a right that takes an afternoon of someone’s work is a right people are quietly discouraged from using.

Free for up to 3 employees, forever

Thirty days with everything included, AI assistant and all, no card and no automatic renewal. When the trial ends, companies with up to 3 employees simply keep working for free. And within the first 60 days you get your money back if it does not fit.

Start free See the demo

Questions? Write to time@irot.com. We answer on working days, usually by the next one.