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Lateral Flow Testing privacy policy

Introduction

The Government of Jersey has an important and vital obligation to protect the ongoing health of islanders and undertake measures to slow the spread of COVID-19. An element of this response is the lateral Flow Testing Regime that is delivered to:

  • educational settings for staff and children
  • workplaces and business
  • direct contacts
  • individuals

More detail relating to Lateral Flow Testing

In order to support the Lateral Flow Testing Programme, there is a requirement to process personal and special category data in order to administer the programme, and maintain an accurate and complete record of an individual’s engagement through registration and test result submissions.

This Privacy Notice outlines and relates specifically to the processing of your personal information to support the Lateral Flow Testing Programme.

The Data Controller for the purposes of the Covid-19 Lateral Flow Testing Programme is the Department for Strategic Policy, Performance and Planning (No 67347) (the "Department"). 

Compliance with the Data Protection (Jersey) Law 2018

COVID-19 Lateral Flow Testing Programme is subject to the provisions of the Data Protection (Jersey) Law 2018 (the "Law") and must comply with all of the data protection principles, including having a legal basis for processing your information.

The legal basis under which the COVID-19 Lateral Flow Testing Programme is operating is:

La Sante Publique

The conditions which the Law allows for the processing of personal and special category personal are:

Schedule 2, Part 2, Paragraph (16) of the Law, which permits the processing of special category data for public health

The processing is necessary for reasons of public interest in the area of public health, including (but not limited to) protecting against cross border threats to health and ensuring a high standard of quality and safety of health care or social care where they are provided for by law and the processing is carried out with appropriate safeguards for the rights and freedoms of data subjects.

The COVID-19 Lateral Flow Testing Programme remain committed to the ongoing protection of your information and compliance with your data subject rights and will act transparently and only collect the minimum amount of information that is needed to respond to COVID-19.

Why we are processing your personal information 

We are processing your information so that we can: 

  • register you on the lateral flow testing programme relevant to you 
  • provide you with a unique registration number  
  • delivery your test packs to your address 
  • enable the submission of test results and maintain a record of your submissions 
  • contact you, where necessary
  • should you submit a positive result, your data will be shared with the Contact Tracing Team, who will ensure that you receive a PCR test to confirm your status

Information we process about you 

We are processing the following personal and special category personal information in order to administer the Lateral Flow Testing: 

  • your contact information, including your full name, mobile telephone number, email address and current residential address 
  • your demographic information such as your date of birth  
  • your workplace and role, if part of the Community Workplace Programme 
  • your school, role or year group if part of the Schools and Educational Settings Programme, whether staff member or student  
  • your status as a direct contact  

How we will collect your information 

The Lateral Flow Testing Portal will enable you to register on the relevant programme, at which point you will be asked to supply your contact details, test result submissions and other information relevant to administering the programme. 

Where your information is kept 

Your information, once collected, is retained within the Lateral Flow Testing Portal. It is shared with the Integrated Public Health Record (IPHR) system if you submit a positive test result.  

All data is hosted in the European Economic Area, in on-island or UK data centres. 

Data sharing 

Should you submit a positive result, your data will be shared with the Contact Tracing Team, who will ensure that you receive a PCR test to confirm your status. For more information about how your information is processed for PCR testing and contact tracing, please visit Government of Jersey coronavirus (COVID-19): privacy notice

Aggregated statistical information is shared with Government Senior Officers, health officials and politicians and published on www.gov.je 

Your data will not be used for any other purpose and will be destroyed in line with Government of Jersey retention schedules. 

Reporting statistics 

Information held about you will be processed by the Public Health Data Analysts. Statistical information will be made available to relevant Government Health Officials, Senior Officers and Politicians in order to: 

  • report on the performance of the programme 
  • analyse the data provided to identify trends and  
  • inform future planning and policy development
  • data reported for these purposes will be aggregated and non-identifiable

Aggregated, non-identifiable statistics will be shared by the Government Communications Team to media outlets, on gov.je and on social media platforms to provide members of the public with insightful information about the Lateral Flow Testing Programme. 

How long we keep information about you 

Information you provide on the Lateral Flow Testing Programme will be retained for as long as the Lateral Flow Testing regime is ‘live’.

Telephone calls 

Queries relating to the Lateral Flow Testing Programme can be made by telephoning +44 (0) 1534 445566. 

Unless we inform you otherwise, telephone calls made by the Government of Jersey are not recorded. If you leave a message on our voicemail systems, your message will be kept until we are able to return your call or make a note of your message. File notes of when and why you called may be taken for record keeping purposes. We will not pass on the content of your telephone calls, unless is it necessary for us to do so; either to fulfil your request for a service; to comply with a legal obligation, or where permitted under other legislation. 

Emails 

If you email us we may keep a record of your email address and a copy of the email for record keeping purposes. For security reasons we will not include any confidential information about you in any email we send to you. We would also suggest that you keep the amount of confidential information you send to us via email to a minimum or use our secure online services where possible or correspond with us by post. We will not share your email address or your email contents unless is it necessary for us to do so; either to fulfil your request for a service; to comply with a legal obligation, or where permitted under other legislation. 

Your rights 

You can ask us to stop processing your information 

You have the right to request that we stop processing your personal data in relation to any of our services. Where possible we will seek to comply with your request, but we may be required to continue to process your information for public health or other lawful reasons. 

You can withdraw your consent to the processing of your information 

Where the collection and processing of your information is carried out on the basis of your consent, you have the right to withdraw your consent to prevent further processing of your personal data. 

However, information collected and processed in response to COVID-19 diagnoses is carried out for public health protection purposes. 

You can request that the processing of your personal data is restricted 

You have the right to request that we restrict the processing of your personal information. You can exercise this right in instances where you believe the information being processed in inaccurate, out of date, or there are no legitimate grounds for the processing. We will always endeavour to consider and comply with your request; however, we may be required to continue to process your information for public health reasons. 

You can ask us to correct, amend or erase your information 

You have the right to challenge the accuracy of the information we hold about you and request that it is corrected where necessary. 

In certain circumstances you can also ask us to erase your information but bear in mind that we may not be able to do this if we have a lawful reason for keeping hold of it. 

You can ask us for a copy of the information we hold about you 

You are legally entitled to request a list of, or a copy of any information that we hold about you. You can submit a subject access request (SAR) using our online form. 

You have the right to query or complain about the use of your information 

You can do this by contacting the Corporate Data Protection Officer by emailing dpo@gov.je or by contacting Jersey Office of the Information Commissioner on +44 (0) 1534 716350 or by emailing enquiries@jerseyoic.org

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