Formal notice (mise en demeure) following refusal of authorisation; lifted by closure letter after the company appointed a new occupational doctor. CDP, December 2019. month-precision date
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
By deliberation n°2019-00395/CDP of 19 April 2019 Senegal's CDP refused SOSAGRIN's authorisation request because personnel without proper authority had access to employees' health data. After the company failed to answer the CDP's correspondence, the CDP issued a formal notice (mise en demeure), citing the processing of workers' medical data by a health professional who was simultaneously the company's deputy director. SOSAGRIN regularised the breaches by appointing a new occupational doctor to handle workers' medical data, and the CDP sent a closure letter lifting the notice. Reported in Avis Trimestriel N°04-2019; the notice date is recorded at quarter-end precision.
HEALTH DATA · CONFLICT OF INTEREST · FORMAL NOTICE · LIFTED
Cite this decision
CDP (Senegal), SOSAGRIN, enforcement notice of December 2019. African Data Protection Enforcement Tracker, Law Lab Africa Research, https://research.lawlab.africa/tracker/senegal/cdp/2019/sosagrin-health-data-formal-notice-lifted/ (accessed 22 July 2026).