MARCH 31, 2021

Personal Data: COVID-19 – Personal data in travel.


Data Privacy & Data Protection Department | Personal Data. Covid 19. Personal Data in Travel.

On 31 March 2021, the Executive Committee of the Global Privacy Assembly (“GPA”) issued a joint statement on the importance of protecting personal data, especially health data, required for domestic and international travel during the COVID-19 pandemic, issuing a series of recommendations for the protection of travelers’ personal data in the context of Covid 19 (the “Joint Statement”).

Through the Joint Statement, the GPA urges governments and other organizations responsible for processing health data for international travel purposes to consider, among others, the following principles, which reflect global data protection principles and practices, among others:

• The application of the principles of “privacy by default” and “privacy by design” should be contemplated in the design of any system, application or data exchange arrangement with respect to the processing of health data for international travel purposes.

• A formal and comprehensive privacy impact assessment on individuals prior to the start of any processing is suggested as a method to ensure that data protection by design principles are implemented in practice and the underlying risks are adequately mitigated.

• Personal data collected, used or disclosed to alleviate the public health effects of COVID-19 require a clearly defined purpose within the broad context of the public health measure. It is advisable to process minimum (not excessive) data and in a way that is proportionate and compatible with the intended purposes and to avoid retaining data longer than necessary.

• Individuals should be informed how their data are used, by whom and for what purpose, providing clear and accessible information, recognizing the geographical, cultural and linguistic diversity of individuals in society who wish to travel.

• The cybersecurity risk of any digital system or application must be fully assessed, taking full account of the risks that may arise from different actors in a global threat context.

Click here to access the GPA Joint Statement.