France Offers Guide For Processing COVID-19 Related Data Under GDPR

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France’s Data Processing Authority CNIL weighs in on Coronavirus and GDPR.

Employers should NOT:

  • Collect in a systematic and generalized manner, or through individual inquiries and requests, information relating to the search for possible symptoms presented by an employee/agent and their relatives.
This means:
  •  No mandatory readings of the body temperatures of each employee
  • No mandatory questionnaires on symptoms

Employers SHOULD:

  • Implement actions to prevent professional risks, and provide information and training.
This means:
  • Educate and invite its employees to self-check.
  • Provide means for reporting symptoms.
  • Promote remote working methods and encourage the use of occupational medicine.

If an employee reports an illness, an employer may record:

  • The date and identity of the person.
  • The organizational measures taken (confinement, teleworking, orientation and contact with the occupational doctor, etc.).

— Employees must inform their employer of any suspected contact with the virus.

— Health authorities may collect health data.

Read CNIL’s full briefing on Coronavirus-related data.

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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