Formal notice (mise en demeure) following refusal of authorisation; lifted by closure letter after the company appointed a new occupational doctor. CDP, December 2019.
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
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
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 30 August 2026).