Coronavirus testing and screening procedures are central to many companies’ return-to-work plans. Because testing and screening data is often sensitive and may help to determine whether individuals are allowed to work, companies need to be aware of the privacy and security risks of collecting this data and protect it appropriately. Failing to do so may lead to a backlash in the workplace, cause reputational damage, and invite scrutiny from regulators and plaintiffs’ attorneys.

We have created checklist of general tips to help companies navigate return-to-work privacy and data security issues. In addition to designing COVID-19 testing and screening data collection programs that fit local and state reopening conditions, companies may also wish to consult key sources of federal guidance, including the following:

• EEOC’s Coronavirus and COVID-19 page, which links to guidance on complying with disability protection and non-discrimination obligations.
• OSHA’s COVID-19 site, which contains a broad array of enforcement guidance, general and industry-specific reopening guidelines, and other resources.
• The CDC’s reopening guidance for businesses and workplaces.

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