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On 30th June 2020 I ran a free GDPR webinar for employers thinking of recording their employees and/or visitors for protection against Coronavirus purposes, setting out the GDPR implications of recording temperatures and other health information about their employees.

As well as a quick recap of GDPR in general, we focused on the key GDPR challenges:

  • Whether processing this data about employees is lawful and what the most appropriate lawful basis is
  • The understanding that even just recording a temperature is considered special category data and has particular protections and that a special condition needs to apply
  • Being clear about whether the recording of this data is absolutely necessary
  • What you need to tell employees
  • Considering the GDPR accountability implications (particularly the need for a DPIA)
  • Some restrictions to consider around automated and monitoring systems
  • And, how to deal with third parties like other employees and NHS Test & Trace if they want details of what you’ve recorded

You can check out a recording of the session below, or here on YouTube and download a copy of the slide pack here.

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