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Information to the interested party on data protection

5.92. AEAT Action Plan against SARS-COV2

Description of the activity

Development of the AEAT Action Plan against SARS-COV2, which may entail:

  • Carry out the necessary actions to protect health and safety, including the management of a record of cases that allows activating 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.


Health protection at work.


It is necessary to process certain data referred to in the EU Regulation, in its article 9, as “special categories of data”.

Thus, article 9.1 of the aforementioned Regulation states that “The processing of data that reveals ethnic or racial origin, political opinions, religious or philosophical convictions, or union membership, and the processing of genetic data, biometric data directed to uniquely identify a natural person, data relating to health or data relating to the sexual life or sexual orientations of a natural person.”

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: “Section 1 will not apply when one of the following circumstances occurs: (…) b) the processing is necessary for the fulfillment of obligations and the exercise of specific rights of the data controller or the interested party in the field of labor law and social security and protection, to the extent authorized by the Union law of the Member States or a collective agreement in accordance with the law of the Member States that establishes adequate guarantees of respect for the fundamental rights and interests of the data subject;".

On the other hand, letter i) of that section 2 establishes that “i) the treatment is necessary for reasons of public interest in the field of public health, such as protection against serious cross-border threats to health, or to ensure high quality and safety levels of healthcare and medicinal products or medical devices, on the basis of Union or Member State law establishing appropriate and specific measures to protect the rights and freedoms of the data subject, in particular confidentiality professional,"


  • Personnel at the service of the AEAT and any other employee, public or private, who performs their duties in AE buildings.


  • DNI, Name and Surname
  • Health, related to COVID-19
  • Employment details (job title, worker history)


  • Collection
  • Record
  • Storage
  • Structuring
  • Modification
  • Update
  • Copy
  • Analysis
  • Enquiry
  • Extraction
  • Promotion
  • Interconnection
  • Limitation
  • Suppression
  • Destruction
  • Other


Transfers or communications of data to medical personnel and health authorities that carry out surveillance of the health of workers are foreseen, in accordance with the provisions of art. 22.4 of Law 31/1995, of November 8, on the prevention of Occupational Risks, or to other competent authorities in the management of this health emergency, in the cases provided for by the regulations.

International transfers

are not foreseen

Planned 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.


Does not apply.

Technical/organizational measures

All data processed has been evaluated through a risk analysis, having obtained a list of technical and organizational measures to apply. These measures have been applied in accordance with the approved adaptation plan.