The spread of coronavirus gives rise to questions about to what extent an employer is allowed to disclose information on infected employees according to the applicable data protection regulation in Greenland.

Earlier this month, the Data Protection Agency published its opinion clarifying to what extent an employer may lawfully disclose information (personal data) on employees in relation to coronavirus.

The authorities made it clear that an employer may to a great extent register and disclose information that is not classified as personal health data and thereby sensitive data. This is, for instance,

  • that an employee has returned home from a “risk area”
  • that an employee is in home quarantine (without mentioning the reason)
  • that an employee is ill (without mentioning what caused the illness)

However, depending on the circumstances, the employer may be entitled to register and even disclose information on the fact that a specific employee is infected. In that way the management and other employees can take the necessary precautions – e.g. consider home quarantine or see a doctor that can examine for infection. This also applies to disclosure of such information to customers, business partners, authorities etc.

Still, the Data Protection Agency emphasizes that the general principles on processing of personal data and the legal requirements for objectivity and necessity must be followed. It must always be considered:

  • if there is a good reason for registering and sharing the relevant information,
  • if it is necessary to specify the information, i.e. if the purpose can be fulfilled by “sharing less”,
  • if it is necessary to mention any names – for instance the name of the infected person and/or person in home quarantine.

If the above give arise to any questions you are welcome to contact our personal data expert.


Thor Suhr
Assistant Attorney

(+299) 58 01 00