As jurisdictions across the world grapple with the effects of the more infectious delta variant, many governments either have taken or are considering more restrictive measures to reduce infection rates and community spread of COVID-19. As we have previously discussed, France is a country that has taken a tougher stance on encouraging COVID-19 vaccinations and has even required employees in certain sectors and industries, in accordance with Article 12, I, of the Law n°2021-1040, to receive a vaccination. The French government also recently introduced the Pass Sanitaire (i.e., health pass). Now, the French Data Protection Authority (“CNIL”) has provided guidance on employers’ obligations regarding collecting health pass information and COVID-19 vaccination data.
Blog Post
September 30, 2021