5.92. AEAT Action Plan against SARS-COV2
Description of the activity
Development of the AEAT action plan against SARS-COV2, which may involve:
- Carry out the actions necessary to protect health and safety, including the management of a record of cases that allows the activation of the corresponding risk prevention measures.
- Collaborate with health authorities.
All of this within the framework of current legal regulations and in compliance with the mandates of the competent health and government authorities in this exceptional situation.
Purpose
Health protection at work.
Legitimation
It is necessary to process certain data referred to in the EU Regulation, in its article 9, as “special categories of data”.
Article 9.1 of the Regulation states that “The processing of data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data intended to uniquely identify a natural person, data relating to the health or data relating to the sexual life or sexual orientation of a natural person are prohibited.”
However, in section 2, a series of exceptions are established in which such data may be processed. Specifically, letter b) of this section 2 indicates the following: “Paragraph 1 shall not apply where one of the following circumstances applies: (…) b) the processing is necessary for the performance of obligations and the exercise of specific rights of the controller or of the data subject in the field of employment law and social security and protection, insofar as this is authorised by Union law of the Member States or by a collective agreement under the law of the Member States which provides for appropriate safeguards regarding the respect of the fundamental rights and interests of the data subject;".
On the other hand, letter i) of that paragraph 2 establishes that “i) the treatment is necessary for reasons of public interest in the area of public health, such as protection against serious cross-border threats to health, or in order to ensure high standards of quality and safety of healthcare and medicinal products or medical devices, on the basis of Union or Member State law which provides for appropriate and specific measures to protect the rights and freedoms of the data subject, in particular professional secrecy,”
Interested parties
- Personnel serving the AEAT and any other employee, public or private, who performs their duties in AE buildings.
Details
- DNI, Name and Surname
- Health, related to COVID-19
- Employment details (job title, employee history)
Treatments
- Collection
- Record
- Storage
- Structuring
- Modification
- Update
- Copy
- Analysis
- Enquiry
- Extraction
- Promotion
- Interconnection
- Limitation
- Suppression
- Destruction
- Other
Recipients
It is anticipated that data will be transferred or communicated to medical personnel and health authorities that monitor the health of workers, as provided for in Article 22.4 of Law 31/1995, of November 8, on the Prevention of Occupational Hazards, or to other authorities competent in the management of this health emergency, in the cases provided for by the regulations.
International transfers
Not foreseen
Expected deadlines for deletion
Personal data will be kept for the time necessary to fulfill the purpose for which it was collected and to determine responsibilities that may arise from said purpose and processing.
Profiling
Does not apply.
Technical/organizational measures
All data processed has been evaluated through a risk analysis, obtaining the list of technical and organizational measures to be applied. These measures have been applied in accordance with the approved adaptation plan.