Regarding the gathering of personal data of employees or contractors, companies must restrain themselves from collecting information concerning possible symptoms that these individuals (or their relatives) might have shown without having obtained prior and appropriate authorization for such processing of sensitive data, provide that their consent for this operation is required by the Colombian Data Protection Legal Framework.

  • Except for the regular periodic medical labor evaluations, there shall not be any imposition to employees to fill any query regarding symptoms nor shall they be obliged to inform in advance their travel plans or any other measures that could be invasive to their privacy.
  • If an employee reports symptoms of sickness or there is reason to suspect that there has been contagion of COVID-19, it is advisable to implement strict security measures over such personal data, without limiting the implementation of registries and supports regarding the measures adopted by the employer. These registries must consider among other measures: i) be subject to restrictions of access, except for the areas in charge; ii) register the minimal quantity of personal data possible; and iii) if possible, be subject to the use of anonymization mechanisms.