Automated processing of personal data by the Ministry of Health and Social Affairs

As part of its activities, the Ministry of Health and Social Affairs collects personal data about categories of people affected, which includes the surname, first name, date of birth, gender, residential address, phone number, email address, employment and place of work or education as well as, where required, information about their legal representatives.

Monitoring the epidemiological situation of the SARS-CoV-2 virus in the Principality 

Information about people affected:

In accordance with the legislation that applies in the Principality of Monaco, with regard to their personal data, the information gathered in the course of "Monitoring the epidemiological situation of the SARS-CoV-2 virus in the Principality" is collected by the State of Monaco/ Ministry of Health and Social Affairs acting in its capacity as the data controller, with the purpose of monitoring the population’s exposure to SARS-CoV-2 and identifying individuals with SARS-CoV-2.

This processing is part of the remit of the Ministry of Health and Social Affairs and is justified by:

• Compliance with a legal obligation resulting from
  • Sovereign Ordinance No. 6.387 of 9 May 2017 on implementation of the International Health Regulations (2005) with a view to controlling the international spread of disease, and the ministerial decision on the processing of personal data to allow monitoring of the epidemiological situation, intended to implement Article 65 of Sovereign Ordinance No. 6.387 of 9 May 2017 on implementation of the International Health Regulations (2005) with a view to controlling the international spread of disease
  • Ministerial Decision of 1 July 2021 amended the Ministerial Decision of 20 May 2020 on the processing of personal data to allow monitoring of the epidemiological situation, intended to implement Article 65 of Sovereign Ordinance No. 6.387 of 9 May 2017 on implementation of the International Health Regulations (2005) with a view to controlling the international spread of disease
  • Ministerial Decision of 2 December 2021 amended the Ministerial Decision of 1 July 2021 pertaining to the health pass, intended to implement Article 65 of Sovereign Ordinance No. 6.387 of 9 May 2017 on implementation of the International Health Regulations (2005) with a view to controlling the international spread of disease
  • Ministerial Decision of 22 November 2021 amended the Ministerial Decision of 24 February 2020, relating to the situation of individuals presenting a risk or signs of potential infection by the 2019 nCoV virus, intended to implement Article 65 of Sovereign Ordinance No. 6.387 of 9 May 2017 on implementation of the International Health Regulations (2005) with a view to controlling the international spread of disease
• Public interest grounds: As part of its health remit, the Department of Health Affairs, under the supervision of the Ministry of Health and Social Affairs is responsible for (Sovereign Ordinance No. 5.640 of 14 December 2015):
  • Ensuring disease prevention and screening
  • Helping to develop and implement emergency plans, and to manage health crises
  • Helping to develop public health policy

The only recipients of the information collected are:

• 
  Information specifically relating to tests:
  
  • The health authorities of the individual’s country of residence in the event of a positive test, in accordance with the International Health Regulations (2005) with a view to controlling the international spread of disease (implemented by Sovereign Ordinance No. 6.387 of 9 May 2017)
  • Monaco Scientific Centre (sub-processor) for identity monitoring
  • The sample taker at the National Testing Centre (for identity monitoring)
• 
  Information specifically relating to vaccination:
  
  • The National Vaccination Centre, in the form of a traceability form
  • Minors and adults subject to guardianship: the legal representative(s)
• 
  Information relating to data that identifies people who have tested positive for COVID-19:
  
  • Individuals whose involvement is strictly necessary to enable implementation of any health measures required to avoid spreading COVID-19
  • The health authorities in the country of residence of the person concerned, in accordance with the International Health Regulations (2005) with a view to controlling the international spread of disease (implemented by Sovereign Ordinance No. 6.387 of 9 May 2017)
  • The attending doctor, at the request of the person concerned
• Data identifying people treated by the National Testing Centre to carry out a test to detect SARS-CoV-2 virus RNA: individuals whose involvement is strictly necessary to carry out the test
• Data identifying people vaccinated against COVID-19: individuals whose involvement is strictly necessary for the purposes of pharmacovigilance or to ensure traceability of the vaccine that a person has received, or to assess the effectiveness of the vaccination with regard to the result of any test carried out on this person
• Information held in health pass certificates: in accordance with Article 5 of the Ministerial Decision on the health pass

Any individual who has proof of a negative result for a virological test (RT-PCR) to detect the SARS-CoV-2 virus, proof of vaccination status or a certificate of recovery following a COVID-19 infection can request the issue of a health pass for Monaco/European Union or for Monaco/European Union/countries which have reached agreements with France and the EU.

The individual must consent to the fact that the information contained in their certificate (surname, first name, date of birth, code enabling verification) will be sent to a French IT system to allow the pass to be generated. When a health pass is checked in the Principality, the person conducting the check can only see the user’s surname, first name and date of birth, and the colour of the health pass. Reading the pass does not allow the person checking it to view any details of the type of proof checked, or the reason why a pass may be deemed invalid.

This data processing is of a temporary nature, in that the personal data collected is kept only for as long as is required to manage the global health crisis associated with SARS-CoV-2, under the provisions of the Ministerial Decision on the processing of personal data to allow monitoring of the epidemiological situation

In accordance with the legislation that applies in the Principality of Monaco, with regard to their personal data, each individual affected has the right of access to personal data relating to them, and the right to request that inaccurate, incomplete or outdated data is corrected, updated or removed.

To exercise these rights or in the event of any questions about the processing of personal data, the individual affected may deliver their request in person or post it to the following address, stating the subject of their request and providing proof of their identity (black-and-white copy of identity document):

Département des Affaires Sociales et de la Santé


(Ministry of Health and Social Affairs)


Place de la Visitation


MC 98000 MONACO

Individuals who have exercised their rights but feel, after contacting the Government, that their rights have not been respected, can submit a complaint to the Data Protection Authority of Monaco (Commission de Contrôle des Informations Nominatives-CCINN): www.ccin.mc