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Knowledge Hub: COVID-19 Contact Tracing Apps in the EU

by LibertiesEU
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Last updated 15 March 2021

European Commission | European Council| European Parliament | Fundamental Rights Agency (FRA) | UN Special Rapporteur on the Right to Privacy | World Health Organization (WHO) | Organization for Economic Cooperation and Development (OECD)



European Commission

Commission Implementing Decision as regards the cross-border exchange of data between national contact tracing and warning mobile applications (15 July 2020): Amending Implementing Decision (EU) 2019/1765 as regards the cross-border exchange of data between national contact tracing and warning mobile applications. The implementing decision means that citizens, in particular those traveling in the EU, will only need to install one app. Read more


Interoperability guidelines for approved contact tracing mobile applications in the EU (13 May 2020): The document addresses the first follow-up action envisaged by the eHealth Network’s 'Mobile applications to support contact tracing in the EU’s fight against COVID-19, Common EU Toolbox for Member States', namely, ‘developing further the interoperability framework’ for mobile contact tracing apps. Read more


Communication: Guidance on Apps supporting the fight against COVID 19 pandemic in relation to data protection (17 April 2020): The document aims to ensure a coherent approach across the EU and provide guidance to Member States and app developers. It sets out features and requirements which apps should meet to ensure compliance with EU privacy and personal data protection legislation, in particular the GDPR and the ePrivacy Directive. The guidance is not legally binding. Read more


Common EU Toolbox for Member States (15 April 2020): The EU toolbox for the use of mobile applications to support contact tracing in the EU’s fight against COVID-19 was developed by the e-Health Network with the support of the European Commission. It explains the essential requirements for national apps, namely that they be voluntary, approved by national DPAs, privacy-preserving and dismantled as soon as they are no longer needed. Read more


Commission Recommendation on a common Union toolbox for the use of technology and data to combat and exit from the COVID-19 crisis, in particular concerning mobile applications and the use of anonymised mobility data (8 April 2020): The purpose is, inter alia, to develop a common European approach (“Toolbox”) for the use of mobile applications, coordinated at EU level, for empowering citizens to take effective social distancing measures, and for warning, preventing and contact tracing to help limit the propagation of the COVID-19 disease. The Recommendation sets out the general principles which should guide the development of such a toolbox and it indicates that the Commission will publish further guidance, including on the personal data protection and privacy implications of the use of applications in this field. Read more


Council of Europe (CoE)

Joint Statement on Digital Contact Tracing (28 April 2020) Summary: The statement underlines the need that measures like contact tracing and the related data processing are appropriate in relation to the goal that they pursue. A fair balance between the interests concerned and the rights at stake needs to be reflected. The Joint Statement lists a number of conditions (like transparency) that need to be fulfilled by tracing apps. Read more


European Parliament

Briefing (April 2020): The briefing discusses contact tracing and other apps to fight the COVID-19 pandemic. It describes initiatives taken by member states and provides a brief analysis of fundamental rights standards and the EU policy framework, including applicable EU rules on data protection and privacy. Read more


Resolution on EU coordinated action to combat the COVID-19 pandemic and its consequences (17 April 2020): (52) The EU Parliament “Takes note of the emergence of contact-tracing applications on mobile devices (......) points out that any use of applications developed by national and EU authorities may not be obligatory and that the generated data are not to be stored in centralised databases, which are prone to potential risk of abuse and loss of trust and may endanger uptake throughout the Union; demands that all storage of data be decentralised, full transparency be given on (non-EU) commercial interests of developers of these applications, (...) demands that the Commission and Member States are fully transparent on the functioning of contact-tracing apps, so that people can verify both the underlying protocol for security and privacy, and check the code itself (...); recommends that sunset clauses are set and the principles of data protection by design and data minimisation are fully observed.” Read more


Fundamental Rights Agency (FRA)

Report (28 May 2020): Coronavirus pandemic in the EU – Fundamental Rights implications: With a focus on contact-tracing apps. Read more

UN Special Rapporteur on the Right to Privacy

Statement (29 October 2020): Joseph A. Cannataci warns about "intrusive, omnipresent surveillance growing during COVID-19 pandemic" at the UN General Assembly in New York. Cannataci voiced concerns about reports of personal and health data being used to exert control over citizens, possibly to little public health effect. He also praised those countries whose response to the pandemic has been proportionate using technology that protects citizens' data. Read more


Annual report (27 July 2020): The report raises concerns that new technologies may be misused to exert control over citizens, with possibly little public health effect. It highlights that one of the main problems is that privacy engineering is "not given due importance". The report praises the DP-3T protocol initiative. It also points out that public health is often placed above fundamental rights: "The need to arrest the spread of a potential epidemic is one of the very few greater goods where public interest is socially valued above the right to privacy". Read more


World Health Organization (WHO)

Interim guidance (28 May 2020): Ethical considerations to guide the use of digital proximity tracking technologies for COVID-19 contact tracing: Interim guidance are intended to inform public health programmes and governments that are considering whether to develop or implement digital proximity tracking technologies for COVID-19 contact tracing. The document covers ethical principles, technical considerations and requirements that are consistent with these principles; and how to achieve equitable and appropriate use of such technologies. Read more


Organisation for Economic Cooperation and Development (OECD)

Policy Paper (23 April 2020): Contribution aimed at preserving privacy when using apps and biometric data in the fight against COVID-19. Read more

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COVID-19 Contact Tracing Apps in the EU

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