# Electronic Monitoring Notice for NEMT Drivers: GPS, Cameras, and App Tracking, With a Signed Acknowledgment

Canonical URL: https://nemtguide.com/templates/electronic-monitoring-notice/ · Updated 2026-10-06

An electronic monitoring notice tells each driver in writing what your company tracks, such as van GPS, the driver app, cameras, and company phones and email, plus when it runs, why, who sees it, and how long you keep it. The driver signs an acknowledgment and you post a copy. New York, Connecticut, Delaware, Maine, and New Jersey each require notice in some form.

- New York, Connecticut, Delaware, and Maine have notice laws for employee monitoring, and New Jersey requires written notice before you track a vehicle an employee drives.
- Since October 1, 2026, Connecticut notices must name the places where monitoring happens, and new hires get a plain-language statement before their first day.
- Maine drivers may refuse your monitoring app on their own phones, and Maine wants notice at the job interview and in writing every year.
- In Illinois, a camera that scans a driver's face needs a written notice, a signed release, and a public retention policy before the first scan.
- California drivers can ask for unedited copies of video event recorder footage, free, within five days.

A NEMT driver is watched in more ways than most workers: the van's GPS, the broker's app, a camera facing the road, sometimes one facing the cabin, and the company phone. A short written notice, signed by the driver and posted where drivers can see it, covers the notice laws in the states that have them and settles questions before they turn into complaints.

This form is that notice. [NEMT GPS tracking](https://nemtguide.com/guides/nemt-gps-tracking/) covers what brokers require you to track, and [NEMT dash cameras](https://nemtguide.com/guides/nemt-dash-cameras/) covers camera requirements, audio consent, and how long to keep footage. This page is the paperwork that tells your drivers about all of it.

## How to use this template

1. **List every kind of monitoring you use in Part 2.** Walk through the vans, the phones, the office, and the yard. Cross out any row you do not use, so the notice says only what you actually do.
2. **Fill in each row honestly.** Write where it runs (van numbers, the office, the yard), when it runs, why you use it, who can see it, and how long you keep it. Use the retention periods you really follow, and check them against your broker contracts. Read the audio consent rules in the dash camera guide before you check the cabin audio row.
3. **Set your limits in Part 3.** Decide when app tracking stops, what happens when a driver will not put an app on a personal phone, and who may view footage.
4. **Add the state parts you need.** Drivers in Connecticut hired on or after October 1, 2026 get Part 4 before their first day. Anyone whose face, fingerprint, or voice a system scans to identify them gets Part 5 before the first scan.
5. **Hand it out at the right times.** Mention monitoring at the job interview, give the full notice at hiring, and get the signature in Part 6 before the first shift. Add it to your [driver onboarding checklist](https://nemtguide.com/templates/nemt-driver-onboarding-checklist/) and keep the signed copy in the [driver file](https://nemtguide.com/templates/nemt-driver-file-checklist/).
6. **Post Part 7.** Put one copy where drivers clock in or pick up keys, and one inside each van.
7. **Log it and repeat it.** Record each driver in Part 8. Give every driver a fresh notice each January, and a new one before you add any new kind of monitoring.

## The template

### Part 1: Company details

| Field | Entry |
|---|---|
| Company name | |
| Address of each office or yard | |
| States where our drivers work | |
| Notice version and date | |
| Who to ask about monitoring (name and phone) | |

### Part 2: What we monitor

We use the electronic monitoring listed below. It applies to every driver, attendant, and dispatcher who uses these vans, phones, or systems.

| What we use | Where it runs | When it runs | Why we use it | Who can see it | How long we keep it |
|---|---|---|---|---|---|
| GPS tracker in each van | | | | | |
| Driver app on a company phone (location and trip times) | | | | | |
| Driver app on your own phone (location and trip times) | | | | | |
| Road-facing camera | | | | | |
| Cabin camera, video only | | | | | |
| Cabin audio recording | | | | | |
| Driver-facing camera with alerts or face scans | | | | | |
| Driving data such as speed and hard braking | | | | | |
| Company phone calls and text messages | | | | | |
| Company email and internet use | | | | | |
| Office and yard cameras | | | | | |
| Other: | | | | | |

**Phones, email, and internet.** Your phone calls and transmissions, email and transmissions, and internet access or use, by any electronic device or system, including computers, phones, wire, radio, and electromagnetic, photoelectronic, or photo-optical systems, may be monitored at any and all times and by any lawful means.

### Part 3: Limits we keep

1. Van GPS and the driver app track work. App tracking stops when you go off shift, at this point: ______.
2. You may say no to installing our tracking app on your own phone. If you do, we will ______ (give you a company phone, or assign you a van with a tracker).
3. We do not use cameras or audio in your home, in your own vehicle, or on your property, unless the job requires it, as follows: ______.
4. We do not monitor restrooms, locker rooms, or break rooms.
5. Only the people named in Part 2 see location data and recordings. We use them for safety, trip records for brokers and Medicaid, crashes, complaints, coaching, and discipline.
6. To ask for a copy of a recording of you, contact ______. In California, you get unedited copies of video event recorder footage free within five days.
7. Riders' information captured by cameras and apps is protected under our privacy policy, and you may not copy or share it.

### Part 4: Connecticut statement for new hires

For drivers who work in Connecticut and were hired on or after October 1, 2026. Give it before the first day of work.

We may monitor without telling you first when we have reasonable grounds to believe an employee is breaking the law, violating the legal rights of the company or its employees, or creating a hostile workplace, and monitoring may produce evidence of it. These are examples of prohibited activities we may monitor that way:

1. Taking fuel, cash, or property that is not yours, including fuel card misuse.
2. Writing false trip times, miles, or signatures.
3. Driving under the influence of alcohol or drugs.
4. Harassing, threatening, or mistreating riders or coworkers.
5. Other: ______

### Part 5: Face scan notice and release

Use this part only if a camera or app scans a driver's face, fingerprint, or voice, for example to confirm who is driving. Illinois requires it before the first scan.

| Field | Entry |
|---|---|
| What is collected (face scan, fingerprint, or voiceprint) | |
| Why we collect it | |
| How long we keep it (until the purpose ends, or 3 years after your last contact with us, whichever comes first) | |
| Where our written policy for keeping and destroying it is posted | |
| Company that stores it for us | |

I was told in writing what is collected, why, and for how long. I agree to the collection described above, and to its storage by the company named above.

| Driver name | Signature | Date |
|---|---|---|
| | | |

### Part 6: Driver acknowledgment

I received this notice on the date below. I read it, or had it read to me, and I had the chance to ask questions. I understand that the company uses the monitoring listed in Part 2.

| Driver name | Date received | Signature | Copy given to driver (Y/N) |
|---|---|---|---|
| | | | |

### Part 7: Posting

Post this part where drivers clock in or pick up keys, and inside each van.

| Electronic monitoring notice | Entry |
|---|---|
| Company | |
| Kinds of monitoring in use | |
| Where it happens (van numbers, office, yard) | |
| Who to ask, and phone | |
| Date posted | |

### Part 8: Notice log

| Driver | Told at interview (date) | Notice signed (date) | Connecticut statement (date or N/A) | Face scan release (date or N/A) | Yearly notice (date) |
|---|---|---|---|---|---|
| | | | | | |
| | | | | | |
| | | | | | |
| | | | | | |
| | | | | | |
| | | | | | |
| | | | | | |
| | | | | | |

## When to give the notice

The timing differs by state. The simplest habit is to cover every step below for every driver, wherever you operate.

| When | What to give | Where the law asks for it |
|---|---|---|
| At the job interview | Tell the applicant you monitor employees | Maine |
| At hiring | The written notice, acknowledged in writing or electronically | New York |
| Before the first day | The statement in Part 4 | Connecticut, hires from October 1, 2026 |
| Before monitoring starts | Written notice of what you monitor | Maine, New Jersey (vehicle tracking), Connecticut |
| Before the first face scan | The notice and release in Part 5 | Illinois |
| Every calendar year | A written notice that you monitor | Maine |
| Before monitoring phones, email, or internet | A one-time acknowledged notice, or an on-screen notice each day | Delaware |

## The state notice laws this form meets

Four states have general laws on notice of employee monitoring. New York's and Delaware's apply to employers with a place of business in the state, and Connecticut's and Maine's cover employers of every size.

- **New York.** Since May 7, 2022, an employer with a place of business in New York that monitors employees' phone calls or transmissions, email, or internet use must give written or electronic notice at hiring, have the employee acknowledge it in writing or electronically, and post it where employees can see it (Civil Rights Law 52-c). The notice must say such use by any electronic device or system may be monitored at any and all times by any lawful means, which is the sentence under Part 2. The attorney general enforces it, with penalties of up to $500, $1,000, then $3,000 per offense. Systems that only manage email, voicemail, or internet traffic for maintenance, without targeting a person, are left out.
- **Connecticut.** Section 31-48d covers collecting information about employees' activities or communications on the employer's premises by any means other than direct observation, cameras included. Public Act 26-73, in effect since October 1, 2026, requires the written notice and the posting to name the types of monitoring and the specific places where they happen, and the posting must go up in those places too. Each employee hired on or after that date also gets, before starting work, a plain-language written statement of the prohibited activities you may monitor without notice, which is Part 4. You may skip notice when you have reasonable grounds to believe an employee is breaking the law, violating legal rights, or creating a hostile workplace and monitoring may produce evidence. The duty to name places also does not apply when you have reasonable grounds to monitor for security and employee safety. The law does not say whether a van counts as premises, so post Part 7 inside each van. Penalties run up to $500, $1,000, then $3,000, and a separate section (31-48b) bars electronic surveillance in rest rooms, locker rooms, and lounges.
- **Delaware.** An employer with a place of business in Delaware may not monitor or intercept an employee's phone, email, or internet use unless it shows an electronic notice each day the employee uses company email or internet, or first gives a one-time notice the employee acknowledges in writing or electronically (19 Del. C. 705). Each violation carries a $100 civil penalty.
- **Maine.** Public Law 2025, chapter 524 (26 MRSA 620-A) became law on January 11, 2026 and took effect July 29, 2026. It requires notice before you start monitoring, a mention during the job interview, and written notice to all current employees at least once each calendar year. It leaves out security and safety cameras, and GPS or other safety devices on vehicles you own that employees drive. It bars audio or video monitoring in an employee's home or personal vehicle, or on their property, unless the job requires it, and lets employees decline monitoring apps on their own devices. Fines run $100 to $500 per violation. The Maine Department of Labor enforces it and offers a free poster that explains it.

## Tracking, camera, and face scan laws

These laws are narrower, but each one touches equipment NEMT companies use every day. The GPS tracking and dash camera guides linked above explain them in full. This is what each one means for the form.

- **New Jersey.** Since April 18, 2022, an employer that knowingly uses a tracking device in a vehicle an employee uses must give the employee written notice, or face penalties of up to $1,000 for a first violation and $2,500 for each later one (N.J.S.A. 34:6B-22). The tracker rows in Part 2, signed in Part 6, are that notice.
- **California.** A tracker on a vehicle needs the consent of its registered owner, lessor, or lessee (Penal Code 637.7). You are that owner for your own vans, so get a driver's written consent before you track the driver's own car. An employee who drives for hire in a vehicle with a windshield video event recorder gets unedited copies of its recordings free within five days of asking (Vehicle Code 26708(b)(13)(F)), which is why Part 3 names who to ask.
- **Illinois.** A scan of face geometry is a biometric identifier, and a plain photograph is not (740 ILCS 14/10). Before collecting one, you must tell the person in writing that it is being collected, the specific purpose, and how long it will be kept, and get a written release (740 ILCS 14/15). For an employee, the release may be one signed as a condition of employment, and since August 2, 2024 it may also be an electronic signature. You also need a public written policy to destroy the data once its purpose is met, or within 3 years of the person's last interaction with you, whichever comes first, and the person's consent before you share it, which is why Part 5 names the company that stores it. Damages are $1,000 per negligent violation and $5,000 per intentional or reckless one, or actual damages if higher. Since August 2, 2024, collecting the same scan from the same person the same way counts as one violation (740 ILCS 14/20).
- **Colorado.** Since July 1, 2026, providers with more than five vehicles must use two-way video dash cameras that capture each Medicaid member's pickup and drop-off, for the primary purpose of safety, driver accountability, and fraud prevention (C.R.S. 25.5-1-802(14)). Write those purposes in the camera rows of Part 2. The [Colorado camera law](https://nemtguide.com/news/colorado-nemt-law-video-cameras/) covers the rest.

Cameras and apps also capture riders. If HIPAA reaches your company, treat that footage and location data as protected health information, as [HIPAA for NEMT](https://nemtguide.com/guides/hipaa-for-nemt/) explains, and point drivers to the privacy rules in your [driver handbook](https://nemtguide.com/templates/nemt-driver-handbook/).

## Frequently asked questions

### How often do I have to give drivers the monitoring notice?

Give it at hiring and get the driver's signature, which New York requires along with a posted copy. Maine adds a mention at the job interview and a written notice to every current employee at least once each calendar year (26 MRSA 620-A, in effect since July 29, 2026). Connecticut hires from October 1, 2026 get the plain-language statement before their first day, and Illinois needs the face scan release before the first scan. A fresh notice each January covers the yearly rule.

### Does the driver have to sign the monitoring notice?

In New York and Delaware, a notice covering phone, email, or internet monitoring must be acknowledged by the employee, in writing or electronically. Delaware also accepts an electronic notice shown each day the employee uses company email or internet. Connecticut counts a posted notice as written notice. A signed copy in the driver file is the simplest proof in every state.

### Can a driver refuse to put the tracking app on a personal phone?

In Maine, yes. Since July 29, 2026, an employee may decline an employer's request to install a data collection or transmission app on a personal device for monitoring (26 MRSA 620-A). In other states, get written consent before you track any phone or car you do not own, and offer a company phone to drivers who say no.

### What changed in Connecticut's monitoring law on October 1, 2026?

Public Act 26-73 rewrote section 31-48d. The written notice and the posted notice must now name the specific places where monitoring may happen, and the posting goes up in those places too. Every employee hired on or after October 1, 2026 gets a plain-language written statement, before starting work, of the prohibited activities you may monitor without notice. Fines stay at up to $500, $1,000, then $3,000.

### Do I need consent before a camera scans a driver's face?

In Illinois, yes. Before collecting a scan of face geometry, tell the driver in writing that it is being collected, why, and for how long, and get a written release, which may be an electronic signature (740 ILCS 14/10 and 14/15). You also need a public written policy for keeping and destroying the data. Damages run $1,000 per negligent violation and $5,000 per intentional or reckless one.

### Can a driver get a copy of the dash camera video?

In California, yes, for a video event recorder mounted on the windshield. An employee who drives for hire, or the employee's representative, can ask for unedited copies of the recordings, and you must give them free within five days (Vehicle Code 26708(b)(13)(F)). Wherever you operate, your notice should say who may see footage and how a driver asks for a copy.

## Official resources

- [Connecticut Public Act 26-73: the monitoring notice law in effect since October 1, 2026](https://www.cga.ct.gov/2026/act/Pa/pdf/2026PA-00073-R00SB-00472-PA.PDF)
- [New York Civil Rights Law 52-c: notice of phone, email, and internet monitoring](https://www.nysenate.gov/legislation/laws/CVR/52-C*2)
- [Maine Public Law 2025, chapter 524: employer surveillance notice](https://legislature.maine.gov/legis/bills/getPDF.asp?paper=HP0025&item=3&snum=132)
- [Maine Department of Labor: Employer Surveillance, Your Rights poster (free to print)](https://www.maine.gov/labor/docs/2026/posters/EmployerSurveillancePoster.pdf)
- [New Jersey P.L. 2021, c.449: written notice for vehicle tracking](https://pub.njleg.gov/bills/2020/PL21/449_.HTM)
- [Illinois Biometric Information Privacy Act, section 15](https://www.ilga.gov/Documents/legislation/ilcs/documents/074000140K15.htm)