As noted by Dr Andrea Jelinek, chair of the European Data
Protection Board (the “EDPB”), in a
statement released on 16 March 2020, laws pertaining to the
protection of personal data are not intended to create unnecessary
obstacles in the global effort to combat the spread of the
coronavirus pandemic
1. That being said, laws such as the General
Data Protection Regulation (EU Regulation 2016/679) (the
“GPPR”) and the Data Protection Act
(Chapter 586 of the Laws of Malta) (the
“DPA”) must be adhered to even during
the present challenging times.
Certain collection and processing of personal data for COVID
purposes may be necessary for the company to identify (and
subsequently reduce) any specific risks the organisation may be
exposed to. This type of collection may include, for example,
systematic data collection through workplace questionnaires or
obliging employees to report their travel plans to the
company’s HR department. The onset of COVID-19 may have
led