During this period of confinement, everyone must implement the measures appropriate to the situation, whether it be limiting travel and meetings or reinforcing hygiene measures. However, employers may not take measures that could infringe on the privacy of the persons concerned. Indeed, avoiding the systematic collection of health data is a procedure to be avoided if its content goes beyond the mere management of suspected exposure to the virus.

Whether by means of questionnaires or individual surveys, employers should therefore not collect information on a generalised basis on the search for possible symptoms present in employees. It is therefore not permissible to implement, for example :

  • mandatory body temperature readings for each employee or visitor to be sent to the management on a daily basis;
  • mandatory body temperature readings for each employee or visitor to be sent to the management on a daily basis;

  • or collect medical forms or questionnaires from all employees.

The employer is responsible for the health and safety of employees/agents. He must therefore implement occupational risk prevention actions, information and training actions, and finally set up an appropriate organisation and means.

In this context, the employer may therefore

  • To sensitize and invite employees to provide individual feedback to him or to the competent health authorities regarding possible exposure;
  • facilitate their transmission by setting up, if necessary, dedicated communication channels with adequate confidentiality;
  • to encourage teleworking.

If a potential problem is reported, an employer may record :

  • the date and identity of the person who was potentially exposed.
  • (e.g. containment, teleworking, contact with occupational medicine, etc.).
  • measures taken such as containment, teleworking, contact with occupational medicine, etc.).

The employer may then communicate to the health authorities, on request, the information relating to the nature of the exposure necessary for the possible care of the exposed person.

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