"The measurement of temperature when entering commercial premises for the purpose of protecting life and health is often unreasonable to believe that it is not subject to the rules of the GDPR when there is no record of results. But if that is the case, and when the question of GDPR arises, read more in the text.
The measurement of the temperature at the entrance to the establishment without recording results shall not constitute the processing of personal data. However, what appears to be the data of an individual when an elevated temperature is measured is a processing in the context of the GDPR and such processing should have its own merits and in accordance with the procedure laid down accordingly. Over here.
To put it simply, the question is what appears and how it deals with such data that the processing would be valid and the privacy of the individual protected.
For example, it is not acceptable that the temperature measuring device is positioned in such a way that the measured temperature is visible to others located close to that person and that the procedure indirectly by other persons on suspicion of the increased temperature is applied after measurement. In such a way, the person would stigmatise and significantly impede its privacy. Furthermore, the question is how to deal with this information, to whom and how to communicate it, whether the person is involved in the work of the work place and how it ensures that the individual and his personal data are protected.
It is important to point out that it is important to ensure and be informed of such type of treatment and to provide all information in accordance with the OPCOM Regulation on data protection to all data subjects before the start of the processing itself.
From this example, we become aware that only measuring the temperature without recording the measurement results does not constitute processing in the context of the GDPR. However, what appears to be the manner in which the temperature is determined is to be treated in the context of the General Regulation and should also be regulated in a valid manner.
- Ensure privacy at temperature reading;
- Ensure the confidentiality of results;
- Prescribe the treatment of suspended persons in order to ensure the purpose of processing and to protect the privacy of those persons;
- Inform in due time of such treatments in accordance with the OPCOM Regulation and ensure the exercise of the right.
Ines I Marko Krečak, dpo Feralis
