Kristof van Quathem of Covington & Burling writes:
In early November, the Dutch Supervisory Authority released an injunction imposed against the public insurance body Uitvoeringsinstituut Werkgeversverzekering (“UWV”) last July.
The UWV allows employers to submit data about their employees for social security purposes. The data includes dates of employee absences due to general illness (and when an employee is pregnant or gave birth, including dates of associated absences and parental leave). While the actual illness is not disclosed, the Supervisory Authority held that the data must be qualified as health data because the mere fact that someone is ill is indicative of their health.
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