Amazon France Logistique – Court Ruling (France, 2025)

In 2023 the French DPA (CNIL) found that, among other things, Amazon France Logistique (the controller) processed three indicators related to the work performance of their employees without a legal basis. The DPA took this finding into consideration when deciding on the fine issued to the controller, i.e. €32 million. The controller contested the decision. The Supreme Administrative Court found that the three indicators (i.e. the stow machine gun indicator, the idle time indicator, and the latency time indicator) were processed lawfully under Article 6(1)(f) GDPR (i.e. legitimate interest). The Court noted that the purpose of the indicators was the management of stock and order (stock machine gun indicator) and to flag interruptions in activity that cannot be detected by the other indicators used in order to identify their causes (idle time indicator and latency time indicator). The Court also noted that the right to private life of the employees was not excessively infringed upon by the processing of these indicators. In contrast, the Court maintained the DPA’s decision regarding the controller's violation of Article 5 GDPR, specifically the principle of data minimisation and accountability, by collecting a disproportionate amount of data and storing them for 31 days without showing the need for such processing. Therefore, the Court found that the controller processed the indicators based on a legitimate interest under Article 6(1)(f) GDPR and reduced the initial fine from €32 million to €15 million.