For the health and safety of our visitors, volunteers and staff, we are recording the name and contact details of everyone who enters a Trust premises to support NHS Scotland’s Test and Protect scheme. This information will be used to enable NHS Scotland to contact you should you have been in the premises around the same time as someone who has tested positive for Covid-19. Contacting people who might have been exposed to the virus is an important step in stopping the spread.

Reasons for data collection

As stated above, the purpose for which we are processing your personal data is to assist with NHS Scotland’s Test and Protect scheme in relation to the Covid-19 public health epidemic. This will involve the gathering and, when necessary, sharing of information with NHS Scotland as the responsible body for Test and Protect.

In order to assist in the containment of the virus, we will only share your data when it is requested directly by NHS Scotland.  This will only be in the unlikely event that there is a cluster of Covid-19 cases linked to a Trust premises. Information will be transferred securely to NHS National Services Scotland who will use the data to contact trace those who were in the premises at the same time as the positive case, and will provide guidance and support to those who may be advised to self-isolate.

Read further information on the NHS Scotland Test and Protect scheme on the NHS website.

Type of data collected

Along with the date and time of your arrival and departure, we will collect the following personal data if applicable:

  • name
  • telephone number (if available)
  • email address

Customer health information will not be requested or stored.

Lawful basis for collecting this data

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 ‘legitimate interests’.
Broadly speaking ‘legitimate interests’ means that we can process your personal information if we have a genuine and legitimate reason and we are not harming any of your rights and interests.

Our legitimate reason for processing your data is to assist with NHS Scotland’s Test and Protect scheme in relation to the Covid-19 public health epidemic.

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

Data retention period

Any personal information which is being held solely for the purposes outlined in Section 10 of our Privacy Notice will be deleted after 21 days.

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

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 access the information we hold about you. Also known as Subject Access Request (SAR).
  • The right to request rectification of any inaccurate personal data we hold about you. In certain circumstances exemptions to these rights may apply.

Further information is available on the Information Commissioner’s Office website.

Do you have a complaint?

If you consider that your personal data has been misused or mishandled by us, you can raise this with the data controller. In this instance, the data controller is the manager of this venue. 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

0303 123 1113

casework@ico.org.uk

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


The content on this page is based on Scottish Government guidance, correct as of 7 August 2020.

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