Data Protection Privacy Notice (COVID-19 Lateral Flow and Testing)
This notice explains what personal data (information) we will hold about you, how we collect it, and how we will use and may share information about you during the online booking process. We are required to notify you of this information, under data protection legislation. Please ensure that you read this notice (sometimes referred to as a ‘privacy notice’) and any other similar notice we may provide to you from time to time when we collect or process personal information about you.
Who collects the information
Staywell Occupational Health Ltd (‘Company’) is a ‘data controller’ and gathers and uses certain information about you.
Data protection principles
We will comply with the data protection principles when gathering and using personal information, as set out by the Faculty of Occupational Medicine.
About the information we collect and hold
The table set out below summarises the information we collect during the COVID-19 testing process, how and why we do so, how we use it and with whom it may be shared.
We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.
Where information may be held
Information may be held at our offices, representatives and agents.
How long we keep your information
The information we collect will form part of your occupational health record.
We may keep the personal information that we obtain about you from the appointment for at least 40 years. This complies with the HSE requirement that health records relating to Control of Substance Hazardous to Health (COSHH) (COVID-19 is classified as a COSHH agent) are kept for at least 40 years. This will be reviewed as the HSE releases further advice on this matter.
Your rights to correct and access your information and to ask for it to be erased
Please contact our head office who can be contacted by email: firstname.lastname@example.org and by phone at 0800 4714941 if (in accordance with applicable law) you would like to request access to information that we hold relating to you or if you have any questions about this notice. You also have the right to ask for some but not all of the information we hold and process to be erased (the ‘right to be forgotten’) in certain circumstances.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that our Head Office can resolve any query or concern you raise about our use of your information. If not, contact the Information Commissioner at https://ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.
As a private occupational health provider, we process data under the following lawful bases outlined by GDPR:
Article 6 (1) (f): processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party.
Article 9 (2) (h): processing is necessary for the purposes of preventative or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems or services.
|The information we collect||How we collect the information||Why we collect the information||How we use and may share the information|
|‘Your name’||From you||Article 6 (1) (f)||This data is collected to identify you and attribute the test result to you. This data will also be passed on to Public Health England in the event of a positive PCR test.|
|‘Date of Birth’||From you||Article 6 (1) (f)||This data is collected to identify you and attribute the test result to you. This data will also be passed on to Public Health England in the event of a positive PCR test.|
|‘Health Information’||From you||Article 6 (1) (f) Article 9 (2) (h)||Health information is collected from the swab test you take, in the form of a positive or negative COVID result. Your individual results will not be sent to your employer. No further health information will be collected during the course of this service.|
|‘Email Address’||From you||Article 6 (1) (f) Article 9 (2) (h)||We may use this information if we need to communicate with you about your test.|
|‘Phone number’||From you||Article 6 (1) (f) Article 9 (2) (h)||In the event you require a PCR COVID-19 test, your result will be provided by text to this mobile phone number.|
|‘Postcode’||From you||Article 6 (1) (f) Article 9 (2) (h)||In the event you require a PCR COVID-19 test, we are required to provide this information to Public Health England if you test positive.|
|‘Anonymised testing data’||From Staywell OH||Article 6 (1) (f) Article 9 (2) (h)||We will provide numbers of positive and negative results to your employer. This data will be anonymised and none of your personal information will be recorded in this report.|
Last updated 11/12/2021