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), as well as to ensure that those that need to evidence their Covid Status are able to do so. To provide the laboratory service, SPPP has partnered with the Health and Community Services (HCS) Pathology department.
This Privacy Notice relates specifically to the processing of your personal information to support the laboratory services provided to the private providers of PCR testing, most commonly for the purposes of pre-departure travel requirements. This process enables the secure and efficient processing of swabs and results reporting to support this service.
How SPPP and HCS process your personal data in other areas of the COVID-19
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 Strategic Policy, Performance and Planning and HCS 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 and HCS 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
In order to ensure that the private providers of PCR tests are able to efficiently and effectively deliver their service to islanders, a laboratory service is being provisioned by the Government of Jersey.
All swabs collected by the private providers will be sent to the PCR testing laboratory in Jersey General Hospital and processed by healthcare professionals in the accredited on-island laboratory. The results will be then reported to the private provider and consequently their customer.
Information collected and processed by SPPP to support their delivery of the service is:
- name
- date of birth
- unique identifier
- contact telephone number
- email address
- address (in Jersey)
- passport number
- date and time or appointment result
Both the private provider and the laboratory service will maintain the agreed standards when processing the data, including assuring data matches across systems and using the agreed identifiers in order to reduce the chances of data errors.
Your data is collected by the private provider and once collected at the time of the test, is inputted into an online form. This online form is submitted and accessed by the laboratory to match against the physical swabs that are delivered to the Jersey General Hospital, securely by the private provider. Data will then be inputted into the laboratory system and the testing procedure is conducted. Results are shared with the Integrated Public Health Record for the purposes of reporting and ensuring that ay positive cases are notified to the Medical Officer for Health, and subsequently sent to the Private Provider to provide you with your certificate.
The ongoing retention of data within these systems is under regular review.
COVID-19 Privacy Policy for information about how your personal information is processed for the purpose of responding to the COVID-19 pandemic.
Information we process about you
We are processing the following personal information:
- 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 Social Security number or other unique identifier
- information about your COVID-19 status (special category data)
How we will collect your information
We will collect information directly from the private provider, who is responsible for ensuring that the data they provide to the laboratory service is up to date, accurate and processed in accordance with the training and contractual obligations.
Data is transferred via a secure portal, processed in the Health and Community Services' pathology information system and accessible only to the private provider and to healthcare professionals within the laboratory service.
It is then sent to the Integrated Public Health Record, and transferred to the Private Providers by automatically generated email.
Where your information is kept
Your information will be stored in the Bookings and Tracing System (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 test result will also be retained in the pathology information system and accessible to clinicians in Health and Community Services via the Patient Information system.
Data sharing
Both SPPP and Health and Community Services will process the data in order to ensure the effective ongoing management of the COVID-19 response, for example, test regimes and contact tracing, and to ensure that test results are accessible to clinicians and healthcare professionals in the event of a requirement to manage your care and treatment.
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.
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.
Telephone calls
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.
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
Below is a summary of your rights. See the
Government of Jersey Data Protection 2018 webpages 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 and therefore, this right may not apply.
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.
Submit a subject access request
gov.je