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Digital proof of delivery: photos, GPS and data protection in Switzerland
Explains how to use photos and location data in digital proof of delivery in a GDPR/DSG-aware way, with practical tips for Swiss businesses.
Quick answer
Photos and GPS provide solid evidence of delivery when used with clear processes, minimal data collection and transparent communication. In Switzerland, the Data Protection Act (DSG) and principles of proportionality apply: collect only necessary data, secure it, and inform recipients about purpose and retention.
What is a digital proof of delivery?
A digital proof of delivery documents with a photo, GPS coordinate or electronic signature that a shipment reached its recipient. It replaces or complements paper confirmations. Couriers typically use a mobile device to record the drop-off location, a photo of the parcel or a short signature.
Legal framework in Switzerland
The Swiss Data Protection Act (DSG) requires purpose limitation, proportionality and transparency. Personal data in delivery photos — such as faces — are sensitive. Avoid collecting unnecessary identification data and assess whether consent or another legal basis is needed, especially for ongoing processing.
Using photos — practical and privacy-safe
Photos are strong proof. Follow these rules: photograph the package or surrounding area, not people’s faces. Strip or avoid storing unnecessary metadata (for example, private geotags). Limit internal access to authorised staff only and log access.
GPS location data — accuracy and purpose
GPS shows where a delivery happened. Store only the accuracy needed for proof. Avoid continuous tracking when only a single drop-off point matters. Record a timestamp, approximate coordinates and the shipment ID. Delete location data after the retention period.
Technical and organisational safeguards
Encrypt data in transit and at rest. Use role-based access controls. Keep access logs and change records. Review third-party apps and supplier contracts for DSG compliance. Define deletion policies and recovery tests.
Transparency towards customers
Tell senders and recipients what you collect, why and for how long. Provide short, clear statements in terms and delivery notices. Offer contact channels for data access requests.
Frequently asked questions
Do I need recipient consent for photo or GPS proofs?
Not always. A one-off, purpose-limited proof can be justified as necessary. For repeated or sensitive processing, consent or another clear legal basis is recommended. Document your assessment.
How long can I retain delivery photos and location data?
Keep data only as long as needed for the proof or as required by law. Set and follow internal retention periods (e.g. 30–90 days) and delete securely when the purpose ends.
Can a delivery photo show a person’s face?
Avoid faces. If unavoidable, apply stronger safeguards and check the legal basis. Prefer photos of the parcel, label or doorstep without people.
What should I check with third-party apps?
Check data processing clauses, storage locations and security measures. Contracts must ensure the supplier processes data in a DSG-compliant way.