Covid 19 Privacy Notice
Who is the Data Controller for this processing?
Sandwell Children’s Trust Limited are the Data Controllers for this processing. This privacy notice is an addendum to our existing privacy notice whilst the current outbreak is ongoing.
What personal information will the Trust process?
The Trust will seek to collect and process personal data in response to the recent outbreak of Coronavirus, which is above and beyond what would ordinarily be processed as a business to determine whether individuals have experienced or are experiencing Covid-19 symptoms or are in any of the high risk-categories which are most vulnerable to become infected and seriously ill.
If the information indicates that you are vulnerable, the Trust may contact you to ensure your wellbeing and safety and to assist you where possible. The processing of such information will be limited to what is proportionate and necessary, taking into account of the latest guidance issued by the Information Commissioner, Government and health professionals, in order to manage and contain the virus. It will enable the Trust to effectively fulfil the functions to keep people safe, put contingency plans into place to safeguard those vulnerable and aid business continuity such as planning and management of resources in the Trust’s services.
What is the legal basis for our use of your personal information?
Under the General Data Protection Regulation (GDPR), the lawful bases the Trust is relying on for using your personal information are:
• to undertake a legal obligation – Article 6 (1) (c ) as per the Coronavirus Act 2020 and for a COVID 19 Purpose, as defined by the Health Service (Control of Patient Information) Regulations 2002′
• to protect your vital interests – Article 6 (1) (d)
• to perform a public task – GDPR Article 6 (1) (e)
Further to this the Trust is also processing special category of personal data which includes data concerning a person’s health on the following lawful basis:
• where it is in your vital interests (Article 9 (2) (c)
• for reasons of public interest in the area of public health (Article 9 (2) (i) as per the Coronavirus Act 2020 and for a COVID 19 Purpose, as defined by the Health Service (Control of Patient Information) Regulations 2002
• for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment, and social protection law – Article 9 (2) (b).
How long will the Trust hold the personal data?
The Trust will hold the personal data for the duration of the COVID -19 pandemic on advice given by the Central Government.
Information provided by staff in relation to this outbreak of COVID-19 will not be used for any other purpose, including to be held within personnel files ‘just in case’ it may be needed again.
When the information is no longer needed for this purpose, it will be securely deleted.
Who your information may be shared with (internally and externally)?
If the Trust is required to, it will only share your information with internal departments and other service providers, contractors and/or partner bodies, but only where it is necessary and as described above. Such as:
• Public Health England
• NHS
• GP practices
• Other Local Authorities
• Local Voluntary Partners
• Emergency Services
• Care providers
• Contracted suppliers who have been procured to provide support and services to our service users.
The Trust will ensure that any personal data in our care will be kept safe and that where your information is disclosed to a third party that they ensure to do the same.
Your personal data will not be used for third party marketing purposes without your prior explicit consent.
What are your Information Rights?
Where processing your personal information is required for the performance of a public interest task (see our lawful bases above), you have the right to object on ‘grounds relating to your particular situation’. The Trust will have to demonstrate why it is appropriate for us to continue to use your personal data.
For more information please see the Information Commissioner’s Data Protection and Coronavirus Information Hub on data handling during the COVID-19 pandemic.