COVID-19 privacy policy

Due to Government guidance, we now seek to collect and process your personal data in response to the recent outbreak of Coronavirus, which is above and beyond what would ordinarily be collected from you, to ensure the safety and well-being of our staff and the general public.
Such information will be limited to what is proportionate and necessary, taking into account of the latest guidance issued by the Government and health professionals, in order to manage and contain the virus. 
Personal data is being collected temporarily in order to assist NHS Test and Trace with requests for that data if needed. This could help contain clusters or outbreaks.
 

What is our lawful basis for processing your personal data?


The General Data Protection Regulation requires specific conditions to be met to ensure that the processing of personal data is lawful. These relevant conditions are below:

  • Article 6(1)(d) – is necessary in order to protect the vital interests of the data subject or another natural person.

    Recital 46 adds that “some processing may serve both important grounds of public interest and the vital interests of the data subject as for instance when processing is necessary for humanitarian purposes, including for monitoring epidemics and their spread”.
 
  • Article 6(1)(e) – is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. 
     

 

Am I required to provide my personal data under a statutory requirement, or am I obliged to provide it?


Whilst the provision of data cannot be mandated, you are strongly advised that it is in the best interests of all to provide this information to us, so we are able to take relevant steps to keep you and others safe.
The information will be managed in a confidential manner. All information will be held securely and processed on a ‘need to know’ basis by only a limited number of people. If there is a need to disclose outside of this, the minimal amount of personal data will be used.
Where Covid-19 related information is to be used for general reporting or statistics, steps will be taken to anonymise the data and general numbers used, wherever possible.
 

How long will my personal data be retained?


To support NHS Test and Trace, we will hold records for 21 days. This reflects the incubation period for COVID-19 (which can be up to 14 days) and an additional 7 days to allow time for testing and tracing. After 21 days, this information will be securely disposed of or deleted.

From the 4th of July we have started our services again. If you would like more information about our new social distancing and enhanced hygiene measures, please take a look at our return to service page here