Privacy Commissioner's FAQ

The Data Protection Authority has prepared a series of FAQs regarding the sensitive issue of personal data processing in connection with the ongoing epidemiological emergency.

Among other information, specific guidelines are provided regarding the possibility of taking employees’ body temperatures at the entrance to the workplace.

It is specified, in fact, that the real-time measurement of body temperature, when linked to the identity of the data subject, constitutes the processing of personal data.

Additional warnings are also provided regarding the use of self-reports or the possibility that the identity of an infected employee might be disclosed to other coworkers. On this last point, the Data Protection Authority states that an employer may not disclose the identity of an infected employee to other workers.

The employer remains obligated to report the names of infected employees to the competent health authorities and to cooperate with them in identifying and tracing the “chain of close contacts” in order to immediately implement the necessary preventive measures.

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