Data Protection under SARS-CoV-2

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Revision as of 16:59, 18 March 2020 by AL (talk | contribs)

General Comments

The sudden and unexpeceted outbreak of cases of COVID-19-Afflictions ("Corona-Virus"), which was declared a pandemic by the WHO has also resulted in extensive data processing activities by EU member states and private companies. This processing activities focus on preventing/slowing the further the spreading of the Corona-Virus and on monitoring the citizen's abidance with governmental measures such as quarantine.

Article 5 Principles

Regardless of the exceptional situation, data processing in connection with measures against the Corona-Pandemic have to comly with the principles of data processing as lined out in Article 5 GDPR:

Principle of lawfulness, fairness and transparency: Data processing must be lawful under Article 6 GDPR and/or Article 9 GDPR. Some member states have already passed laws that deal with the Corona-Virus which must be taken into consideration when assessing the lawfulness of the processing. See below for more information. Furthermore processing must be fair and transparent. This includes i.e. that data subjects whose data is being processed for purposes of fighting the Corona-Virus must be informed under Article 13 GDPR or Article 14 GDPR once their data has been obtained.

To be continued.

Legal Basis under Article 6

To be added soon...

Legal Basis under Article 9

To be added soon...

DPA Guidelines

In the context of the Corona pandemic, the EU/EEA Data protection authorities released guidelines on the processing of personal data. You can have a look at the list below. Feel free to edit it!


The Data protection authority (the DSB) issued guidelines here.


The Data protection authority (the Datatilsynet) issued guidelines here.


The Data protection authority (the AKI) issued guidelines here.


The Data protection authority (the CNIL) issued guidelines here.


The Federal Data protection authority (the BfDi) issued guidelines here, as well as the DPA of Bradenburg, see here.


The Data protection authority (the HDPA) issued guidelines here.


The Data protection authority (the NAIH) issued guidelines here.


The Data protection authority (the Persónuvernd) issued guidelines here.


The Data protection authority (the DPC) issued guidelines here.


The Data protection authority (the CNPD) issued guidelines here.

The Netherlands

The Data protection authority (the AP) issued guidelines here.


The Data protection authority (the Datatilsynet) issued guidelines here.


The Data protection authority (the IP) issued guidelines here.


The Data protection authority (the Datainspektionen) issued guidelines here.

The UK

The Data protection authority (the ICO) issued guidelines here.


The EDPB issued a statement here.