Companies worldwide are scrambling to respond to the current
global COVID-19 pandemic, addressing critical and monumental health
and safety risks, coping with operational and logistical challenges
presented by erratic and/or reduced customer activity, and
supporting remote employee working. Urgently, companies are putting
together procedures for the collection of sensitive employee health
information to detect and/or prevent the spread of the virus and
are struggling with what to say and whom to tell when confirmed or
suspected diagnoses arise. On top of these challenges, more than 20
U.S. and global data protection authorities and governmental
agencies have issued diverse and divergent guidance on health data
collection, COVID-19 diagnosis disclosure and work-at-home
practices.1