How to Facilitate a Safe and Privacy Compliant Return to Work: Contact Tracing

Organizations are evaluating whether they can safely bring employees back to the workplace while keeping the COVID-19 outbreak under control, and some are considering a form of contact tracing to track potential spread and contact points for illness and exposure. This third installment of our three-part article series on how to facilitate a safe and privacy compliant return to work will address the challenges of contact tracing and provide steps to take when rolling out the technology, as well as how to ensure that an overall workplace pandemic plan is effective. Part two provided practical advice from Mastercard, Johnson Controls and outside privacy counsel on protocols for identifying and responding to symptomatic or sick employees, including six considerations for developing a policy. Part one examined the relevant laws and guidance, as well as how to balance competing interests of safety and privacy, and what to expect from U.S. regulators. See “FTC and ICO Commissioners Discuss the Problems With Pandemic Tech and Their Enforcement Approaches” (May. 20, 2020).

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