DATA PRIVACY NOTICE – COVID 19 -

HOW WE USE PERSONAL INFORMATION COLLECTED TO ASSIST WITH NHS SCOTLAND’S TEST AND PROTECT STRATEGY 

The congregation of Kilmallie and Ardnamurchan Free Church of Scotland in the Presbytery of Inverness, Ross and Lochaber

This privacy notice explains the way in which Kilmallie and Ardnamurchan Free Church uses, or “processes” personal information collected to assist with Test and Protect.  Personal information is any information, held either in paper records or electronically, from which you can be identified, such as your name, address, email address or telephone number.  The processing of personal information is governed by data protection law. “Processing” is anything that is done with personal information, from collection onwards.

The Congregation, jointly with the Presbytery, is the “data controller” in terms of data protection regulations as we decide on the purposes and means of how your personal information is processed.  Our contact details are provided below. 

Introduction 

For the health and safety of people to this building, we are recording the name and contact details of everyone who enters to support Test & Protect. This information will be used to enable NHS Scotland and statutory partners to contact you should you have been in the premises around the same time as someone who has tested positive for coronavirus. Contacting people who might have been exposed to the virus is an important step in stopping the spread.

1. Why do we need to collect this data?

As stated above, the purpose for which we are processing your personal data is to assist with NHS Scotland’s Test & Protect strategy in tackling the coronavirus public health epidemic. This will involve the gathering and, when necessary, the sharing of information with NHS Scotland and statutory partners. Your data will not be used for any other purpose.

In order to assist in the containment of the virus, we will only share your data when it is requested directly by NHS Scotland and statutory partners.  This will only be in the unlikely event there is a cluster of coronavirus cases linked to the premises. 

For further information on the NHS Scotland Test and Protect strategy please visit the NHS website.

2. What data will we collect?

Your name, contact telephone number (or alternatively postal or email address), date and time of your arrival and departure.

3. What is our lawful basis for collecting this data?

https://www.informationgovernance.scot.nhs.uk/use-of-your-data-for-track-trace-isolate-tti/

Under data protection law, GDPR Article 6(1), we have a number of lawful bases that allow us to collect and process personal information. In this case, the lawful basis for processing your data is your express consent. 

Before sharing any information we will carefully consider and balance any potential impact on you and your rights.

4. How long will we retain the data?

Your personal data will be retained only for the purposes stated in this privacy notice and will be held by us for no more than 3 weeks (21 days).

All personal data will be held and disposed of in a safe and secure manner.

5. Your rights

As defined in the data protection law, GDPR Article(s) 12-23, you have the following rights: 

The right to be informed about the collection and use of your personal data. This is outlined above.

The right to erasure.  If at any point within the 21 days after your visit you decide you’d like us to delete the personal data you provided, please advise us and we will delete all information related to you. 

The right to object to us processing your personal data. If you do so, we will delete all the personal data we hold in relation to you.

The right to rectification.  If the information held is in any way incorrect, you can contact the data controller and request that the information be rectified.

In certain circumstances exemptions to these rights may apply.  Further information is available on the Information Commissioner’s Office website. 

6. Do you have a complaint?

If you consider that your personal data has been misused or mishandled by us, you can raise this with us, the congregation. You can contact us by pastor@kilmalliefreechurch.org

If you remain dissatisfied you can make a complaint to the Information Commissioner, who is an independent regulator. The Information Commissioner can be contacted at:

Information Commissioner’s Office Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, or 0303 123 1113, or casework@ico.org.uk.

Any complaint to the Information Commissioner is without prejudice to your right to seek redress through the courts.

https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/exemptions/