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authority (dpa) have recently changed their positions in this respect. the employment ministry allows temperature checks, but only during the covid- pandemic and provided that the decision to introduce such checks, as well as the method of implementation, is included in the company's work rules in line with
regulation (gdpr) does not apply. if, on the other hand, any data is recorded – which, according to the dpa, will, for example, inevitably be the case to justify an employee being refused access to the workplace – this will count as the processing of health data. according to the dpa, in such a case and with...
https://www.altius.com/blog/731/temperature-checks-the-employment-ministry-s-new-position