For the health and safety of the customers/visitors and staff at our buildings and venues, we are recording the name and contact details of people who enter to support NHS Scotland’s efforts in tackling COVID-19. This information will be used to enable NHS Scotland and statutory partners to contact you should you have been at a building or venue 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.
Some of our services already capture customer data for appointments and bookings, and some of our services will start to operate appointments systems to manage customer demand as our services re-open. Where this is the case, we will also use names and addresses provided for booking for the purposes of Test & Protect for 21 days from the day of your visit, though we may retain your data for Council purposes for a longer time.
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 venue you visited.
Where we don’t operate a customer bookings or appointments system for the purpose of delivering a particular service, participating Council venues who are capturing customer details either prior to arrival or on arrival are doing so only for the purpose of Test and Protect.
For further information on the NHS Scotland Test and Protect strategy please visit the NHS Inform website.
Why do we need to collect this data?
As stated above, some of our services already capture customer data for appointments and bookings, and some of our services will start to operate appointments systems to manage customer demand as our services re-open. Where we don’t operate a customer bookings or appointments system, participating Council venues are only gathering this data for the purpose of assisting with NHS Scotland’s efforts 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.
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.
What data will we collect?
Along with the date and time of your arrival and departure, we will collect the following personal data if applicable:
- your name; and
- contact telephone number.
If you do not have a telephone number, you have the option to provide:
- a postal address; or
- an email address.
What is our 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. Where we capture customer data to operate a bookings or appointments process for the purpose of providing a particular service, the legal basis will be included on the Privacy Notice for the service, which will be shown to you before you book, but are also available to browse here. Where we are only for test and protect purposes, or where we are using data we already capture for another purpose for Test and Protect 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 strategy in relation to the coronavirus public health epidemic.
Before sharing any information, we will carefully consider and balance any potential impact on you and your rights.
How long will we retain the data?
Where we are capturing customer data only for the purposes of Test & Protect, 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).
Where we are using customer data we capture for appointments or booking purposes as well as for the purposes of Test & Protect, we will retain your data for the period identified in the Privacy Notice for the service, which will be shown to you before you book, but are also available to browse here. We will only use this data for the purposes of Test & Protect for 21 days.
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 for the purposes of Test & Protect, 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 for the purposes of Test & Protect.
- 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.
Do you have a complaint?
You have rights in relation to your data, including the right to object or to ask for a copy of it. See more information about the rights you have as well as the contact details for the Council’s Data Protection Officer. You also have the right to make a complaint to the Information Commissioner’s Office if you think we haven’t handled your data properly.