Yes. Many employers have been using devices such as GPS in company cars in order to track how fast employees are driving, how long a break they are taking (monitoring how long the vehicle has not moved), and where employees are located. GPS has also been used to track the movements and whereabouts of employees on or off the job, by placing tracking chips in cell phones. In one case, the attachment of a GPS device to an employee’s personal vehicle as part of an employer’s investigation amounted to a workplace search that fell within the workplace exception to the warrant requirement, and thus did not require a warrant. However, the search was considered unreasonable because the scope exceeded work hours. See Matter of Cunningham v. New York State Dept. of Labor, 21 N.Y.3d 315 (N.Y. 2013). While some unions have fought to protect workers against this type of monitoring, at this time, little law exists to protect workers against it.