On Saturday, 14 March 2020, the Italian Government and the National Trade Unions signed a Protocol (document in Italian here) that calls for the introduction of safety measures at the workplace, with the aim of containing the spread of the Covid-19 virus. These measures will remain in effect on the entire territory of Italy until March 25, 2020 and are in addition to those already in place further to the various emergency decrees enacted last week (see our newsletter here).

Here is a summary of the main measures introduced by the Protocol:

  • Temperature checks when accessing the workplace
    Upon arriving at work, employees may have their temperature checked. If their temperature is 37.5°C or higher, access to the workplace will be denied. In such a case, the employee will have to be momentarily isolated from other workforce, will be given a mask and will be required to contact their doctor for further instructions.


  • Managing employees who get sick at work
    Employees who feel ill at work, with cough or shortness of breath, will have to immediately inform their HR manager. The concerned employee will have to be isolated from other workforce, while the employer informs local health authorities and receives instructions on what to do.


  • Information to workforce
    Employers must inform employees, as well as anyone else who enters the workplace, that access shall be denied to those who, in the last 14 days, have had contacts with individuals who have tested positive to CoVid-19 or who have travelled to a risk area as per indications of the WHO.


  • Privacy compliance
    Checking an employee's temperature entails treatment of personal data. Consequently, the following guidelines must be complied with:

    • identify the employee and record his/her temperature only if it is above 37.5°C, as a means to document the reason why access to the workplace is denied;
    • provide information on the treatment of personal data even verbally, by making reference to the prevention measures introduced to fight the spread of COVID-19;
    • identify those who will take the temperature of employees (e.g. first aid personnel) and provide them with necessary instructions. It is advisable to have said personnel sign an agreement to ensure they keep confidential any information they receive in performing this activity;
    • in case an employee is momentarily isolated from other workforce, ensure that measures are in place to safeguard the person's privacy and dignity.

    Furthermore, any statement received by individuals, confirming that they have not been in contact with others who have tested positive to Covid-19 or have not travelled to infected areas, entails treatment of personal data. Therefore, this information should be collected only for the purpose of avoiding the spread of the virus. For example, information concerning the identity of the person who has tested positive or the area where the person has been to, should not be asked.


  • Access of suppliers to the workplace
    Companies will have to plan access of external suppliers, in a way so as to minimize contact with workforce. If possible, drivers will not leave their vehicles. When loading and unloading goods, a minimum distance of 1 meter will be kept between personnel used for this purpose.


  • Individual protective measures
    When employees are required to work at less than 1 meter from one another and it is not possible to organize working activity differently, employers will have to provide concerned workforce with masks and other protective measures, such as gloves, caps, lab coats, etc.


  • Management of communal areas (canteen, change rooms, smoking areas, vending machines)
    Only small groups will be allowed in communal areas at any given time. Proper ventilation must also be guaranteed, as well as ensuring a minimum space of 1 meter between individuals.


  • Workforce management (shift work, change in production line, clock-in clock-out)
    In addition to what provided for- in previously enacted decrees, employers will be entitled to make changes to production lines, by changing shifts with the aim of minimizing personal contacts between employees working each shift. Clock-in and clock-out times should also be spread out so as to avoid crowds and minimize time spent in communal areas.


  • Sanitizing the workplace
    Employers will have to clean the workplace on a daily basis and ensure that it is sanitized periodically. In case an employee is tested positive to Covid-19, a strict protocol must be followed when sanitizing the company's premises.


  • Collaboration between employers and works councils / workers' representative for safety aspects.
    A committee between employer, internal works councils members and the workers' representative for safety aspects will be set up in each company, to monitor the application of the rules contained in the Protocol. Employers must also collaborate with the designated company doctor when implementing safety measures.

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