A number of European institutions, agencies and bodies (EUIs) have implemented body temperature checks as part of the health and safety measures adopted in the context of their “return to the office” strategy as an appropriate complementary measure, among other necessary health and safety measures, to help prevent the spread of COVID-19 contamination.

At the same time, systematic body temperature checks of staff and other visitors to filter access to EUIs premises may constitute an interference into individuals’ rights to private life and/or personal data protection. The EDPS observes that body temperature checks can be implemented through a variety of devices and processes that should be subject to careful assessment. The EDPS has decided to issue the present orientations to help EUIs and Data Protection Officers (DPOs) meet the requirements of Regulation (EU) 2018/1725 (the Regulation), where applicable.

EDPS comments on the Commission draft implementing decision amending Implementing Decision 2019/1765 as regards the cross-border exchange of data between national contact tracing and warning mobile applications with regard to combatting the COVID-19 pandemic.

In public health, contact tracing is the process to identify individuals who have been in contact with infected persons. Proximity tracing with smartphone applications and sensors could support contact tracing. It involves processing of sensitive personal data.
What is Contact Tracing?

During epidemics of infectious diseases, such as the Coronavirus disease (COVID-19), it is important to lower the number of new infection cases and to stop it eventually. Therefore the infection chain of onward transmissions must be interrupted. When those persons known to be infected reveal their recent contacts, other infected persons may be identified, informed and e.g. isolated already early on, even before they become aware of their infection. The process to identify contacts of known cases is called contact tracing.
A person becomes a contact of a primary case by e.g. face-to-face contact within a short distance over some time span, physical contact or spending time indoors together–all within the incubation period of e.g. up to 2 weeks for the coronavirus disease.

To establish the risk exposure in contact tracing, information about the distance between the persons and the duration of contact are important. Close contacts with high-risk exposure may then become subject to different rules or treatments.

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Introductory remarks by Wojciech Wiewiórowski  at the committee for European Affairs of the senate of the Republic of France (via videolink).