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Safer Travel Policy: pre-registration for inbound travel (COVID-19): privacy notice

​Introduction

Strategic Policy, Planning and Performance ("SPPP") has an important and vital obligation to protect the ongoing health of Jersey's general public and undertake measures to slow the spread of coronavirus (COVID-19).

This Privacy Notice relates specifically to the Government's processing of your personal information to support the Safe Travel Policy. This policy requires all those travelling to Jersey to identify themselves, and demonstrate their Covid Status, therefore minimising the cross-border infections.

Strategic Policy, Planning and Performance privacy policies

Compliance with the Data Protection (Jersey) Law 2018

Whilst responding to COVID-19 we remain 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.

Unless otherwise stated, the legal basis for the Government processing your personal information (including special category data) as described below is that it necessary for reasons of public health protection (Schedule 2, Art.16).

We remain committed to the ongoing protection of your information and compliance with your data subject rights.

SPPP will continue to comply with the principles of the Law 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 personal information in order to reduce the risk of COVID-19 transmission into Jersey and to manage the risk of community transmission on the island pursuant to the Safe Travel Policy.

All arriving passengers are required to supply a limited amount of personal information by completing the pre-departure registration online form. Provision of this information is a statutory requirement.  

If someone else completes the form for you, your personal information will be collected from them on the pre-departure form. Please be aware that, if someone else has provided their contact details for you on the form (for example, where one party has completed the pre-departure form on behalf of everyone in a party traveling together and supplied only their contact details for all test results) those contact details may also be used for further PCR tests conducted at a later stage. If you are not happy for that party to receive your test results, please ensure you provide your own contact details on the pre-departure form or notify the Covid Helpline of the correct contact details to be used when attending future tests.

Anyone completing the form on another person's behalf will be asked to proceed only if they have your authority, and if submitting information on behalf of a child, hold parental responsibility. 

Information collected and processed includes:

  • name 
  • date of birth
  • contact telephone number 
  • email address 
  • address (in Jersey)
  • air or sea travel, port of departure, date of arrival in Jersey, carrier and reason for travel

From the 2 November 2021, when travelling into Jersey you will also be asked if you wish to demonstrate your vaccination status, your recent recovery from Covid and/or your recent negative test status (Covid-Status). Whilst you are under no obligation to provide this information, demonstrating Covid-Status may affect whether you are required to take a test or self-isolate on arrival. 

If you were vaccinated in Jersey and you wish to demonstrate your vaccination status, you will be asked to provide your Social Security Number (JY number). When you provide this, your Social Security number will be matched with your vaccination record, and we will provide you with confirmation of your status by email. This will be generated automatically, however, should you wish to dispute the result, you may do so by speaking to a border official. At no point will your health record be accessible to anyone other than your GP and the Vaccination Centre.

If you were vaccinated or tested elsewhere, you will be asked to provide details of the type of vaccination and the dates of vaccination. This data will be used to determine your testing or isolation requirement and will be shared with the IPHR for Monitoring and Enforcement purposes. You are required to bring evidence of your COVID Status with you and provide it on request on arrival in Jersey. However, a copy of this evidence will not be retained.

Your data is collected on the covidsafe.je and transferred to the IPHR (Integrated Public Health Record). The ongoing retention of data within these systems is under regular review.

Ports of Jersey, Jersey Customs and Immigration Officials or health officials stationed at the ports will access your information on your arrival in Jersey to verify that your details are correct. They will also request evidence relating to the COVID Status that you have declared. This is to ensure compliance with the requirements of the Safer Travel Programme and COVID-19 (Screening, Assessment and Isolation) (Jersey) Regulations 2020.

Should you be required to take a PCR test or you have chosen not to demonstrate your status and are required to self-isolate, the Government of Jersey will maintain regular contact with you by text message or telephone. You are obliged to respond to these communications and if self-isolating, the Government of Jersey (or one of the local enforcement agencies) may visit you at your address in Jersey.  Where required your information will be shared with law enforcement agencies. 

Please note that texts or emails relating to tests taken other than at the port of entry may be sent to the contact details stored in the person record of the IPHR, which may differ to the contact details provided on the pre-departure form.

If you are aware that contact details previously provided to the Government are no longer accurate you will need to update them.

Update your contact details

The COVID-19 Privacy Policy for how your personal information is processed for the purpose of testing, monitoring and enforcement and contact tracing.

Information we process about you

We are processing the following personal information as part of the response to COVID-19:

  • 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 recent whereabouts and travel history, including your flight and ferry details
  • your Social Security number (if you have been vaccinated in Jersey and choose to demonstrate your vaccination status when travelling into Jersey)
  • information about your COVID Status, such as your vaccination, recovery or negative test status (special category data)

How we will collect your information

We will collect information directly from you by way of the online pre-registration travel form.

On arrival in Jersey, you will be asked to show border officials the QR code that was sent to you on completion of the form. You will also be asked to show your photo identification.

If you have advised us that you wish to demonstrate your COVID Status, you will be asked to evidence your vaccination, recovery or negative test status using official documents, as outlined in the Safe Travel guidance. No evidence or identification is retained.

The border officials will advise you of your entry status and whether you will be required to undertake a PCR test or whether there are other regulations that you must follow. Your entry status is then confirmed in the covidsafe.je portal, and transferred to IPHR.

Travelling to Jersey guidelines (Safer Travel)

Where your information is kept

Your information will be stored in the covidsafe.je portal (Microsoft) and transferred to a dedicated COVID-19 Integrated Public Health Record system (Dynamics 365) with secure backend database hosted within the Government's Azure environment. Your vaccination status data is stored in the FHIR repository, also hosted on the Government's Azure environment and is accessed for this purpose as a 'look-up'.

Data sharing

SPPP share data with the COVID in the Infrastructure, Housing and Environment Department in order to ensure the effective ongoing management of the COVID response, for example, test regimes and contact tracing, as well as monitoring and enforcement.

Limited personal information is shared with Statistics Jersey who use the data for a range of statistical and analytical purposes – personal data is anonymised or pseudonymised where-ever possible before it is shared and used for statistical purposes.

We will also share information about you with law enforcement agencies where it is necessary to enforce the COVID-19 (Screening, Assessment and Isolation) (Jersey) Regulations 2020, such as to conduct compliance checks or inform you of the requirement to self-isolate.

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

Your data will only be shared if the law allows us to or failing that we will seek your consent. We will only share the information that is relevant at the time and not your whole record.

Publication of your information

Statistical information will be published on the Government of Jersey website, or other media, where relevant, to keep members of the public informed. All statistical information is strictly anonymised. 

How long we keep information about you

Unless indicated otherwise in this notice, the information you provide to us will be retained for the length of time necessary for the purpose it was collected. Currently, we cannot specify how long this will be, as it will depend on the duration of the pandemic and GoJ COVID Safe policies, and whether the information may be required in the event that the virus remerges.

The ongoing retention of your information is to be reviewed every six months.

Emails

Once you have submitted your form, you will receive a confirmation email that advises you of the information you provided, your requirements on arrival and the QR code that denotes your COVID Status when scanned at the border.

If you email us we may keep a record of your email address and a copy of the email for record keeping purposes.

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

This is a summary of your rights. Refer to Government of Jersey Data Protection information for further details on how to exercise 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 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.

Questions or complaints

If you have a query or concern regarding how your data is being processed, please contact the Government of Jersey Corporate Data Protection Officer by emailing dpo@gov.je.

If you consider that the Government has contravened or is likely to contravene the Data Protection (Jersey) Law 2018 and the contravention affects your rights in respect of personal data, you have the right to lodge a complaint with the Jersey Office of the Information Commissioner. This can be done by emailing enquiries@jerseyoic.org.

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