FR CNIL Covid Monitoring Sytems


On Sep. 14, CNIL issued opinion on SI-DEP, Contact Covid, StopCovid.


  • CNIL published its new opinion on the conditions for implementing SI-DEP and Contact Covid files, StopCovid mobile application, set up by government to fight against Covid.
  • Followed May 2020, FR CNIL issued opinion on SI-DEP and Conta ct Covid, see #77664.
  • Followed Sep. 2020, CNIL decided to close formal notice of Jul. 20, 2020 addressed to the Ministry of Solidarity and Health re StopCovid app data processing, see #76601.
  • Key Points
  • Found systems put in place in the context of the health crisis (SI-DEP and Contact Covid files, StopCovid application) are, for the most part, respectful of personal data.
  • Most recommendations made by the CNIL in its opinions were taken into account.
  • However, CNIL noted certain bad practices and approached the organizations in question so that they could comply as soon as possible.
  • The CNIL requests that indicators be put in place in order to assess more precisely the contribution of these devices to the management of the health crisis.
  • A second phase of checks will begin before the end of September 2020, results will be communicated in next public notice from CNIL on the processing operations concerned.
  • SI-DEP
  • SIDEP file is a national information system which allows the centralization of the results of SARS-CoV-2 tests carried out by public or private laboratories.
  • Contact Covid
  • Implemented by National Health Insurance Fund (CNAM) collects information on contact cases and chains of contamination.
  • Surveys carried out at 3 different levels including authorized health insurance staff.
  • Found unsatisfactory practices re insufficiency, in certain cases, of mechanisms capable of guaranteeing data retention limited to the period provided for by the texts.
  • Delivery of information to the persons concerned, which is sometimes incomplete.
  • Exercise of individual rights, no formalized procedure in some regional health agencies.
  • And finally, re the security of data transmissions between certain organizations.
  • StopCovid App
  • Voluntary mobile contact tracking application, using Bluetooth technology.
  • Made available by Government as part of its strategy of progressive deconfinement.
  • It allows users to be alerted to a risk of contamination when they have been near another user who has been diagnosed or screened positive to COVID-19.

Regulators FR CNIL
Entity Types CNSM; Corp; Ins
Reference PR, 9/14/2020; Dec 2020-087, 9/10/2020; GDPR Reg 2016/679
Functions Compliance; Legal; Operations; Privacy; Reporting; Technology
Countries France
Products Corporate; Insurance; Insurance-Health
Regions EMEA
Rule Type Guidance
Rule Date 9/14/2020
Effective Date 9/14/2020
Rule Id 86196
Linked to N/A
Reg. Last Update 9/14/2020
Report Section EU

Last substantive update on 09/16/2020