How to Facilitate a Privacy Compliant Return to Work: Policies and Protocols (Part Two of Three)

Balancing health and safety concerns with privacy considerations after the coronavirus pandemic can be overwhelming for a fund manager when bringing its workforce back into the office. This second article in our three-part series outlines how to facilitate a privacy compliant return to work, and it provides practical advice from various in-house and outside privacy counsel on protocols for identifying and responding to symptomatic or sick employees. The article also includes six considerations to assist fund managers with developing a privacy compliant policy. The first article examined the relevant laws and guidance; ways fund managers can balance competing interests of safety and privacy; and anticipated U.S. regulatory considerations. The third article will focus on contact tracing and considerations for deciding if, and in what form, it is appropriate for a fund manager. See “Are You Prepared for OCIE’s Sweep of Business Continuity Plans and Coronavirus Actions?” (Jun. 2, 2020).

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