White & Case set out an overview of the key issues for organizations to consider during the COVID-19 crisis, from a French and EU data protection compliance perspective:
- Organizations should consider undertaking a Data Protection Impact Assessment before collecting personal data from individuals relating to the coronavirus disease.
- Organizations must have an appropriate legal basis for processing personal data collected from individuals relating to the disease.
- Other issues to consider from a data protection compliance perspective include: disclosure of cases to personnel, responding to individual rights requests, local law requirements and guidelines, remote working policies, data security, third-party data sharing, voluntary disclosure by affected data subjects, and the handling of personal data of deceased data subjects.
- Monitor regulatory guidance issued in response to the outbreak.