DoD has issued expanded force protection guidance that calls for the collection of COVID-19 related information from individuals whose place of duty is in the DoD workplace. The guidance broadly calls on military and civilian components to restrict worksite access to essential personnel only – and in implementing those restrictions personal information may need to be collected.
The guidance says that all personally identifiable information must be safeguarded, and components may only collect, use, maintain and or disseminate the minimum amount of PII necessary to prevent the spread of COVID-19 and to protect personnel in DoD workplaces.
DoD provided the following URL for the form (“Personnel Accountability and Assessment Notification for Coronavirus Disease (COVID-19) Exposure”):
https://www.esd.whs.mil/Portals/54/Documents/DD/forms/dd/dd3112.pdf – but as of the time this article was published the file could not be accessed.
The EEOC recently addressed workplace concerns regarding Coronavirus related information – saying that an employer must store separately from the employee’s personnel files any information it obtains about an employee related to the virus, including the results of taking an employee’s temperature or the employee’s suspicion, or self-identification, of having been infected.
DoD says the new policy does not conflict with the EEOC guidance, which was issued in the context of the Americans with Disabilities Act and the Rehabilitation Act – which applies to the federal workforce – and the Coronavirus.
Workers also are being advised to notify supervisors if they manifest any symptoms of the viral infection, to include cough, fever and shortness of breath.
Sick persons are being advised to follow CDC guidelines as well. Persons who are not sick but that could face exposure to the virus should notify their supervisor and maintain a minimum of six feet of distance from others.
Mission-essential personnel who are healthy should expect to comply with daily screening (to include temperature checks), wear masks and protective gear, not share headsets or other objects normally used near or on the face, and disinfect their workspaces regularly and often.
Service members and personnel stationed in states with work-at-home orders in place should report to work only if directed to do so by their commander or supervisor. Telework should be maximized.