Processing of Personal Data for Monitoring the COVID-19 Pandemic

Everything you need to know about Santé publique France’s processing of personal data through the surveillance systems established in response to the COVID-19 pandemic

In accordance with its legal and regulatory mandates (Articles L. 1413-1 and R. 1413-1 of the Public Health Code) and responsibilities (Articles L. 1413-7 and L. 1413-8 of the Public Health Code), Santé publique France processes personal data based on the performance of a mission in the public interest, with the purpose of responding to public health alerts (Article 67 of Law No. 78-17 on Information Technology, Data Files, and Civil Liberties).

In addition to the investigations carried out for crisis management—particularly cluster investigations requiring the use of directly identifiable data—Santé publique France conducts epidemiological surveillance using pseudonymized data (i.e., data that does not allow for the direct identification of individuals, specifically by removing the last names, first names, and precise contact details of the individuals concerned) from the following information systems:

SIDEP, Contact Covid, Vaccin Covid

Information system for COVID-19 screening of the population (SI-DEP) under the responsibility of the Directorate General for Health (Decree No. 2020-551)

This data is processed by Santé publique France for epidemiological surveillance purposes, particularly for the production of indicators. Subject to legislative changes (Article 11 I. Law No. 2020-546), the pseudonymized data from this system will be retained by Santé publique France until April 1, 2021. 

Please note that in the context of cluster investigations and health inquiries, regional staff of Santé publique France may access the personal data of the individuals concerned to the extent strictly necessary for the performance of their duties. This data is deleted three months after collection. 

“Contact Covid” information system under the responsibility of the National Health Insurance Fund (Decree No. 2020-551)

This data is processed for epidemiological surveillance purposes. Subject to legislative changes (Article 11 I. Law No. 2020-546), pseudonymized data from this system will be retained by Santé publique France until April 1, 2021. 

“Covid Vaccine” information system under the joint responsibility of the National Health Insurance Fund and the Directorate General of Health (Decree No. 2020-1690)

Pseudonymized data from this system will be retained for 10 years and are processed for the purpose of monitoring vaccination coverage and measuring vaccine efficacy.

The transmission of pseudonymized data from these three systems to authorized agents of Public Health France precludes the possibility for data subjects to object to such processing.

SARS-CoV-2 Virus Sequencing Data – EMERGEN Project

As part of the response to the public health alert, in the event of a positive result, biological samples may undergo genomic sequencing of the virus. The results of this sequencing, along with certain pseudonymized data regarding the affected patients, will then be transmitted to Santé publique France and Inserm/ANRS MIE as part of the EMER-GEN project, which aims to characterize the various SARS-CoV-2 variants circulating in France. The data are used for Santé publique France’s surveillance and alert missions and may, subject to CNIL authorization, also be made available to researchers while respecting your privacy. 

The data transmitted includes the following: sample number, patient’s year of birth, department of residence, sequencing indication, date of sample collection, name and ZIP code of the collecting laboratory, name of the laboratory responsible for sequencing, date of receipt of the sample for sequencing, date of result delivery, type of sequencing, and its result (Nextstrain clade).

You may exercise your rights to object, access, rectify, erase, and restrict your data by contacting dpo@santepubliquefrance.fr or Santé publique France, Data Protection Officer, 12 rue du Val d’Osne, 94415 Saint Maurice Cedex.

For more information