Covid-19: in restaurants, the “reminder notebooks” cropped by the CNIL

First, there were the exit permits to be completed during confinement. Six months later, other sheets appeared in restaurants located in the maximum alert zone: the reminder notebooks. Sometimes simple loose sheets, sometimes recycled school notebooks or downright high-tech tablet, they must be used to trace customers in the event of contamination of one of them.

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The idea is simple, and many other countries are applying it: customers indicate their last name, first name and phone number and are called if their table neighbor reports Covid-19 to health authorities. Except that some customers are already reporting abuses: establishments would also request email addresses, others would run the same notebook for all the tables.

On social networks, some young women even testify to having been annoyed by unscrupulous waiters, even customers who took advantage of the reminder books to retrieve their phone number …

No commercial solicitation

On Wednesday October 7, the Cnil therefore published its recommendations so that the collection and processing of this personal data comply with the regulations. Already, only one means of contact must be requested: it is a telephone number or an email address, but not both.

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Unsurprisingly, these contact details should only be used to search for “contact cases” and only at the request of the health authorities. ” Any other use, for example inviting customers to a theme party or sending a satisfaction questionnaire, is strictly prohibited. », Recalls the authority in charge of the protection of personal data. A restaurant owner who would take advantage of the epidemic to build up a client file risks fines of up to € 300,000.

A model for restaurateurs

The data should also not be kept for more than 14 days, and only the head of the establishment should have access to it. Beyond the health risks, a notebook which passes from table to table with the contact details of each one does not therefore comply with the regulations. The Cnil recommends instead an individual form and proposes a model to be completed to facilitate the work of restorers.

Finally, the organization recalls that it is forbidden to ask for an identity card or proof to ensure the identity that the customer discloses. What also makes opponents say that the measure is ineffective: no one can ensure that the phone number is really that of the customer.


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