The Privacy Protection Authority (the "PPA") has
published a guideline (the "Guideline") regarding privacy
protection of the data of visitors which is collected upon their
entering the premises of businesses. The Guidelines provide
parameters for stores and businesses which are required by the
Emergency regulations (New Coronavirus – Restrictions on
Activities), 2020 (the "Emergency Regulations") to ask
those persons entering their premises questions about their health.
Under the Guidelines, such businesses are required to respect the
overarching privacy principles of consent, purpose limitation and
proportionality when questioning the visitors.
Under the Emergency Regulations, businesses are required to ask
the visitors whether they have been coughing, whether their
temperature is higher than 38 degrees Celsius (currently or in the
past week) and whether they had close contact with a Coronavirus
patient in the past two weeks. It is preferable for the business
