SOSAGRIN

Formal notice (mise en demeure) following refusal of authorisation; lifted by closure letter after the company appointed a new occupational doctor. CDP, December 2019.

Record ID

sn-cdp-2019-0002

Jurisdiction

Senegal

Regulator

CDP

Type

enforcement notice

Date decided

December 2019

Respondent type

private

Sector

agriculture

Violations

workers' medical data processed by a health professional who was also the company's deputy director (conflict of interest), obstruction of the CDP's follow-up (no response to correspondence)

Provisions cited

Loi n°2008-12 du 25 janvier 2008, délibération n°2019-00395/CDP du 19 avril 2019

Outcome

formal notice (mise en demeure) following refusal of authorisation; lifted by closure letter after the company appointed a new occupational doctor

Status

final

Source

Official document ↗

Source integrity

SHA-256 a026478cab7840c3…

Record verified

30 July 2026

The facts

Sosagrin applied to the CDP for authorisation to process an employee register containing workers' personal data. By deliberation of 19 April 2019 the Commission refused, because employees' health data was accessible to unauthorised personnel: the workers' medical data was handled by a health professional who was at the same time the company's deputy director. When Sosagrin did not answer the Commission's letters, the CDP put it on formal notice for that conflict of interest and for obstructing the Commission's action.

Orders and outcome

Following the formal notice Sosagrin regularised the breaches by appointing a new company doctor to handle workers' medical data, and the CDP sent a closure letter lifting the formal notice. Dated 2019.

HEALTH DATA · CONFLICT OF INTEREST · FORMAL NOTICE · LIFTED

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