This privacy notice explains and provides you with information about how Wirral Council collect and hold information about you, in relation to the unprecedented challenges we face as a result of the Coronavirus pandemic (COVID-19).
Our General Privacy Notice gives you more information about how we collect, process, protect and dispose of personal data in general. It also give you information about your rights as a data subject.
What information do we collect and how will we use it?
We are committed to responding to the best of our ability to help coordinate the community response for COVID-19. Therefore we may need to collect basic details about you including your name, address, telephone number and email address.
Dependent on your circumstances and how the current pandemic and government advice emerges the Council may need to ask for more detailed information about you. This might include personal data relating to your current health or medical condition. We may also ask for a unique identifier such as your National Insurance Number or NHS Number to help identify you.
The Council may also need to ask you for sensitive personal data that you have not already supplied, for example, your age or if you have any underlying illnesses or are vulnerable. We can then use this information to assist you and prioritise our services.
We may ask you for information to help us identify and understand about those suffering with, or at risk of suffering with, COVID-19. This could be information about:
- incidents of exposure to COVID-19
- the management of outbreaks of or the risk of COVID-19
- locating, contacting, screening, flagging and monitoring Covid-19 incidents
- information about providing services in relation to testing, diagnosis, self-isolation, fitness to work, treatment, medical and social interventions and recovery from COVID-19
The Council already holds information about you, which you will have provided for a specific reason. In normal circumstances we would seek to inform you that the data provided would be used for a different reason. However, due to the rapidly emerging situation regarding COVID-19, this will not always be possible.
During this pandemic we may ask you for and process information about you, which is above and beyond what would normally be collected. This is entirely to ensure your safety and well-being. Please be assured, this will be limited to what is proportionate and necessary.
We work in line with current Government guidance, to help us manage and contain the virus and enable us to effectively keep you safe. We have contingency plans in place to safeguard those who are vulnerable and to aid business continuity.
What is the lawful basis for processing this data?
The legal basis for processing your data is that it is in the public interest for the Council to deal with the outbreak of COVID-19.
The General Data Protection Regulation (GDPR) requires specific conditions are met to ensure that the processing of personal data is lawful. These relevant conditions are listed below:
- Article 6(1)(d) GDPR - processing is necessary in order to protect the vital interests of the data subject or another natural person.
- Article 6(1)(e) GDPR – processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
The processing of special categories of personal data, which includes data concerning a person’s health, are prohibited unless specific further conditions can be met as follows:
- Article 9(2)(i) GDPR – processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health.
- Schedule 1, Part 1(3) Data Protection Act 2018 – processing is necessary for reasons of public interest in the area of public health, and is carried out by or under the responsibility of a health professional, or by another person who in the circumstances owes a duty of confidentiality under an enactment or rule of law.
- Article 9(2)(g) GDPR - processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.
The legislations, policies and guidance that relate to this service include, but are not limited to:
- The Civil Contingencies Act 2004 and (contingency planning) Regulations 2005 Allows the local authorities continue to exercise its functions in the event of a emergency
- The Local Government Act 2000 - Give powers to local authorities to promote economic, social and environmental well-being within District
- Care Act 2014 - legal framework for local authorities support the individual’s ‘wellbeing’
Who are we likely to share this information with?
We are in unprecedented times and during this current pandemic, we may need to share your personal data internally across our service areas as well as externally with other public authorities, emergency services, and other stakeholders.
It would not be practical for the Council to give an exhaustive list of parties for whom sharing may take place as Government guidance is ongoing and adapts and changes to meet the requirements of the pandemic.
Retention and Destruction of your information
Wirral Council seeks to only retain your information for as short a time as is necessary. This retention timeframe takes into account current Government advice.
The minimum timeframe for the information outlined in this privacy notice will be for the duration of the COVID-19 response. Where possible your personal data will be anonymised. All information will be confidentially disposed of when no longer required to be held.
Wirral Council will not process your personal data in any manner which is inconsistent with or does not embody the spirit of the principles of The Data Protection Act 2018, incorporating General Data Protection Regulations (GDPR)
There is further information about how Wirral Council handles personal data available on our general Privacy Notice.
If you have any questions or queries in relation to this Privacy Notice please contact:
Data Protection Officer
Telephone: 0151 691 8645