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Coronavirus Test and Trace Privacy Notice


Details of what information we collect from you, what we do with it and who it might be shared with.

As a customer/visitor of a Tunbridge Wells Borough Council owned site you will be asked to provide some basic information and contact details. The following information will be collected:

  • the names of all customers or visitors, or if it is a group of people, the name of one member of the group
  • a contact phone number for each customer or visitor, or for the lead member of a group of people
  • date of visit and arrival time and departure time

In addition, if you only interact with one member of staff during your visit, the name of the assigned staff member will be recorded alongside your information.

To support NHS Test and Trace (which is part of the Department for Health and Social Care) in England, we have been mandated by law to collect and keep a limited record of staff, customers and visitors who come onto our premises for the purpose of contact tracing.

By maintaining records of staff, customers and visitors, and sharing these with NHS Test and Trace where requested, we can help to identify people who may have been exposed to the coronavirus.

The use of your information is covered by the General Data Protection Regulations Article 6 (1) (c) – a legal obligation to which we are subject to. The legal obligation to which we are subject means that we are mandated by new regulations from the government to co-operate with the NHS Test and Trace service, in order to help maintain a safe operating environment and to help fight any local outbreak of corona virus.

Maidstone Borough Council stores your information on our behalf. View the Maidstone Borough Council privacy information.

We do not transfer personal data outside the UK, or the EU.

We are responsible for the collection of your personal data and will be responsible for compliance with data protection legislation for the period of time we hold your information.

When that information is requested by the NHS Test and Trace service, the service would at this point be responsible for compliance with data protection legislation.

The NHS Test and Trace service as part of safeguarding your personal data, has in place technical, organisational and administrative security measures to protect your personal information that it receives from us, from loss, misuse, and unauthorised access, disclosure, alteration and destruction.

If another customer at the venue reported symptoms and subsequently tested positive, NHS Test and Trace can request the log of customer details for a particular time period (for example, this may be all customers who visited on a particular day or time-band, or over a two day period).

This information will not be used for other purposes, and NHS Test and Trace will not disclose this information to any third party unless required to do so by law (for example, as a result of receiving a court order).

Future government guidance may also require us to provide information that we would usually collect and hold onto as part of our ordinary dealings with you (perhaps, for example, your name, date of birth and phone number).

NHS Test and Trace have asked us to retain this information for 21 days from the date of your visit, to enable contact tracing to be carried out by NHS Test and Trace during that period. We will only share information with NHS Test and Trace if it is specifically requested by them.

Where the information is only collected for the purpose of contact tracing, it will be destroyed by us 21 days after the date of your visit.

Other information that we may be required to share will continue to be held after 21 days and we will use it as we usually would, unless and until you tell us not to.

By law, you have a number of rights as a data subject, such as the right to be informed, the right to access information held about you and the right to rectification of any inaccurate data that we hold about you. These rights are not absolute, but you may contact us using the details below if you wish to exercise any of these rights.

If you wish to complain or would like to exercise your rights regarding how your information is used, you should contact the Data Protection Officer at:

Email: dataprotection@tunbridgewells.gov.uk

Telephone: 01892 554077

By post:

Data Protection Officer
Tunbridge Wells Borough Council
Civic Way
Royal Tunbridge Wells
Kent
TN1 1RS

If you are still not satisfied, you can complain via the Information Commissioner’s Office website.