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By Audrey BERTOLOTTI and Katrien BAETENS, Linklaters LLP*
As the Covid-19 vaccination process gathers steam, employers around the world consider what their vaccination strategy will be once (and if) the vaccine becomes available to all employees. In this context, companies examine to what extent they can require employees to take the vaccine and/or restrict those who are not vaccinated from entering the workplace.
The Luxembourg Data Protection Authority (“CNPD”) addressed on 11 February 2021 some of these issues in its recommendations with respect to personal data collection in the Covid-19 sanitary crisis context (the “Recommendations”). We have summarised below how the CNPD proposes to answer some of the most pressing questions of the...
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