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Service
Covid-19 Response
Privacy notice

Last updated: 31 July 2020 

The following privacy notice applies to information processed in aid of Warwickshire County Council’s Covid-19 response. It should be read in addition to the council’s overall Customer and Staff Privacy Notices. 

Warwickshire County Council is the Data Controller for the personal data it collects about you and remains committed to handling your data appropriately, in line with Data Protection legislation.   

Where your personal data is used as part of the Community Shielding Hubs it will only be used for those specific purposes of ensuring you are provided with the food, social support, wellbeing and medication packages in line with the Central Government guidance and subsequent Memoranda of Understanding. 

Purpose for processing

The Department of Health and Social Care has served notice under Regulation 3(4) of the Health Service (Control of Patient Information) Regulations 2002 (COPI) to require Warwickshire County Council to process confidential patient information for purposes set out in Regulation 3(1) COPI. 

The council will collect and use your personal information in order to manage and mitigate the spread and impact of the current outbreak of Covid-19: 

  • to protect public health 

  • to provide public health and social care services to the public 

  • to monitor and manage the Covid-19 outbreak and incidents of exposure. 

  • for the purposes of research Health and social care data, including ‘confidential patient information’ including physical/mental health 

  • for the purposes of posting and sharing Community led Support Groups contact details on websites (WCC’s and partners) 

  • to ensure social distancing is considered in traffic modelling in order to promote safe town centre recoveries from Covid-19 and to promote safe, active travel to relieve the pressure on public transport. 

Information collected and processed will enable the Council to fulfil our obligations to keep people safe, ensure contingency plans, aid business continuity, and safeguard those considered high risk or vulnerable as a result of the outbreak.

Personal information collected and lawful basis

Your personal information processed will include, but is not limited to: 

  • Name 
  • DoB/Age 
  • Gender 
  • Ethnicity 
  • Occupation 
  • Contact information – home address, telephone numbers, email address
  • Unique Property Reference
  • Personal Reference Numbers – NHS number 
  • Dietary requirements 
  • Lifestyle and social circumstances 
  • Mental / physical and learning disabilities
  • Health information
  • Information relevant to your needs during the outbreak or your support needs if you are a carer
  • Car registration used to receive a test at a regional test centre 
  • Mobile number given to receive test results by text 
  • Visual Images - Transport Planning use Artificial Intelligence Monitoring Equipment (AIME) - low resolution cameras and Artificial Intelligence software – for social distancing analysis for the purpose of transport planning and not enforcement. No facial recognition, and no Automatic Number Plates Recognition (ANPR) will be processed by WCC in relation to AIME. 

Our lawful bases for processing this personal information are as follows: 

  • GDPR Article 6(1)(e) processing is necessary for the performance of a task carried out in the public interest. 

  • GDPR Article 6(1)(a) Consent to the processing for posting and sharing on websites the contact details of Community led Support Groups 

Special Category personal data is processed for the following lawful bases: 

  • GDPR Article 9(2)(g) – processing is necessary for reasons of substantial public interest,  

  • DPA 2018 Schedule 2 (6) – Statutory and governmental purpose to process and share this data. 

  • DPA 2018 Schedule 1 Part 2 – Substantial public interest 

The Council also has a statutory requirement to process any such confidential patient information for purposes set out in Regulation 3(1) of the Health Service Control of Patient Information Regulations 2002 (COPI) under the notice dated 20th March 2020 issued to them by the Secretary of State for Health and Social Care under Regulation 3(4) of COPI (the COPI Notice) until 20th September 2020. 

Who we may share your information with

We may share your information with:

  • Our providers
  • Clinical Commissioning Groups
  • Community Groups
  • Coventry and Warwickshire Partnership Trust (CWPT)
  • Coventry City Council
  • COVID-19 testing centres: Ricoh Arena (Coventry); Sixways Stadium (Worcester); Edgbaston Stadium (Birmingham) 
  • Department for Environment, Food and Rural Affairs (DEFRA) 
  • Tesco PLC  
  • Department of Health and Social Care, and all arm’s length bodies of that department
  • George Eliot Hospital (GEH)
  • GP practices
  • NHS Digital
  • NHS England
  • NHS Improvement
  • North Warwickshire Borough Council
  • Nuneaton and Bedworth Borough Council
  • Police • Rugby Borough Council
  • South Warwickshire NHS Foundation Trust (SWFT)
  • Stratford District Council
  • University Hospital Coventry and Warwickshire (UHCW)
  • Warwick District Council
  • Volunteers and charities
  • Other central government departments as appropriate
  • Other providers of healthcare or NHS bodies where appropriate
  • Other local authorities where appropriate

We will only share relevant information where necessary to respond to the Covid-19 outbreak. All sharing will be in line with the requirements of the Health Service (Control of Patient Information) Regulations 2002 (COPI) and Data Protection Act 2018.

How long we will hold your information

Your information will be retained only for as long as necessary, for the duration of the Covid-19 outbreak.  Data specifically provided to the Council to provide Community Shielding Hubs in response to the Covid-19 outbreak will be returned to the Government department and deleted from WCC servers in line with Government procedures and Memorandum of Understanding.

Personal data provided by customers who are vulnerable and/or facing financial hardship due to Covid-19 and are eligible for food parcel deliveries provided by Tesco PLC via the Council and DEFRA will have their personal data retained for a maximum of 18 months. 

Your information rights

Find out how to access your personal information

You are entitled to a copy of, or a description of, the personal data we hold that relates to you, subject to lawful restrictions. How to request this using the online secure form

You may be entitled to rectification, restriction, objection, and erasure of your personal information depending on the service and lawful basis. Emailed requests should be made direct to the Information Rights team at [email protected] 

See the council’s overall privacy notice for further contact details and if you have a complaint about your information rights. 

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