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Baden-Württemberg: LfDI Baden-Württemberg plans to conduct random checks for data deletion post-pandemic

The Baden-Württemberg data protection authority ('LfDI Baden-Württemberg') announced, on 8 April 2022, that as soon as the COVID-19 pandemic is over it will review all pandemic-related restrictions, including interventions on the fundamental right to informational self-determination which served to combat the pandemic. In particular, the LfDI Baden-Württemberg noted that after the pandemic, all of the measures relating to the pandemic lose their justification, hence the LfDI Baden-Württemberg will approach, among other things, healthcare providers, such as test centre operators and pharmacies, for data processed in the context of the pandemic response, but also other companies and public bodies that have stored 3G evidence of their employees and customers. In addition, the LfDI Baden-Württemberg emphasised that where appropriate, it will insist on the prompt deletion or blocking of this data, noting that this is important to prevent misuse or even abuse of this sensitive data.

Furthermore, the LfDI Baden-Württemberg noted that in future, health information, such as information on pregnancies or autoimmune diseases of employees, must not be used inappropriately, for example to terminate employment contracts or to deny promotion. Moreover, the LfDI Baden-Württemberg stated that it will also scrutinise the state's powers of intervention, which were justified by the fight against the pandemic, noting that due to the pandemic, numerous and in some cases novel data processing operations became necessary, from immunisation status to contact details to proof of the result of a COVID-19 test. Lastly, the LfDI Baden-Württemberg clarified that data collected and stored must be deleted when it is no longer needed for the pandemic response.

You can read the press release, only available in German, here.