Collection of Personal Data - Privacy Notice
Introduction
For the health and safety of the customers and staff in these premises, we are recording the name and contact details of everyone who enters to support NHS Scotland’s Test and Protect. This information will be used to enable NHS Scotland to contact you should you have been in the premises around the same time as someone who has tested positive for coronavirus. Contacting people who might have been exposed to the virus is an important step in stopping the spread.
Reasons for data collection
As stated above, the purpose for which we are processing your personal data is to assist with NHS Scotland’s Test and Protect strategy in relation to the coronavirus public health epidemic. This will involve the gathering and, when necessary, the sharing of information with NHS Scotland as the responsible body for Test and Protect. Your data will not be used for any other purpose.
In order to assist in the containment of the virus, we will only share your data when it is requested directly by NHS Scotland. This will only be in the unlikely event there is a cluster of coronavirus cases linked to the venue. Information will be transferred securely to NHS National Services Scotland who will use the data to contact trace those who were in the establishment at the same time as the positive case, and will provide guidance and support to those who may be advised to self-isolate.
Read further information on the NHS Scotland Test and Protect strategy on the NHS website at:
www.informationgovernance.scot.nhs.uk/use-of-your-data-for-track-trace-isolate-tti/
Type of data collected
Along with the date and time of your arrival and departure, we will collect the following personal data if applicable:
If you do not have a telephone number, you have the option to provide:
Customer health information will not be requested or stored.
Lawful basis for collecting this data
Under data protection law, GDPR Article 6(1), we have a number of lawful bases that allow us to collect and process personal information. In this case, the lawful basis for processing your data is 'legitimate interests'.
Broadly speaking 'legitimate interests' means that we can process your personal information if we have a genuine and legitimate reason and we are not harming any of your rights and interests.
Our legitimate reason for processing your data is to assist with NHS Scotland’s Test and Protect strategy in relation to the coronavirus public health epidemic.
Before sharing any information we will carefully consider and balance any potential impact on you and your rights.
Data retention period
Your personal data will be retained only for the purposes stated in this privacy notice and will be held by us for no more than 3 weeks (21 days).
All personal data will be held and disposed of in a safe and secure manner.
Your rights
As defined in the data protection law, GDPR Article(s) 12-23, you have the following rights:
the right to be informed about the collection and use of your personal data. This is outlined above.
the right to erasure. If at any point within the 21 days after your visit you decide you’d like us to delete the personal data you provided, please advise us and we will delete all information related to you.
the right to object to us processing your personal data. If you do so, we will delete all the personal data we hold in relation to you
the right to rectification. If the information held is in any way incorrect, you can contact the data controller and request that the information be rectified.
In certain circumstances exemptions to these rights may apply. Further information is available on the Information Commissioner’s Office website at:
www.ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/exemptions/
Complaint procedure
If you consider that your personal data has been misused or mishandled by us, you can raise this with the data controller. In this instance, the data controller is the manager of this venue.
If you remain dissatisfied you can make a complaint to the Information Commissioner, who is an independent regulator. The Information Commissioner can be contacted at:
Post: Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF
Telephone: 0303 123 1113 Email: casework@ico.org.uk
Any complaint to the Information Commissioner is without prejudice to your right to seek redress through the courts.
Content
If you develop COVID-19 symptoms during your visit, do not ignore or try to hide your symptoms. It is important you act quickly to help yourself and protect those around you. It is your responsibility to stay safe and keep others safe.
COVID-19 symptoms are:
If you feel unwell and experience any COVID-19 symptoms you must:
Do not ignore your symptoms: self-isolating and getting tested quickly is the best way that you can stay safe and protect others.
You MUST notify your accommodation provider.
If you need medical advice while you wait for your test results, please contact your regular (home) GP or call 111.
If you are staying or travelling with others, they must also self-isolate and take appropriate action based on your test result.
What should I do if my test is positive?
Full guidance can be found on GOV.UK
What to do if you cannot return home from your holiday accommodation
The accommodation provider and guest should discuss next steps as soon as possible.
If the guest is unable to return home, the accommodation provider and guest should discuss meal and laundry provision, and accommodation providers should consider whether symptomatic guests should clean their own rooms and strip their own beds.
Unless otherwise provided for in the contractual terms of the booking, the guest will be expected to pay the costs of an extended stay in all but exceptional circumstances.
Exceptional circumstances may include but are not limited to where the accommodation provider has failed to follow government guidance to create a covid-secure environment.
There will be some types of accommodation where self-isolation would not be possible, for example if there are shared washing facilities or if the risk to the host, owner or staff cannot be mitigated. In these cases, guests should make arrangements to travel home as safely as possible, whilst minimising risk to others.
Accommodation providers should consider how best to inform guests about their policy for Covid-symptomatic guests, for example during the booking or check-in process.
Guests should follow government guidance on dealing with possible or confirmed coronavirus (COVID-19) infection.
Once the guest (and if appropriate their family) has finished the required self-isolation period and is no longer symptomatic, they should return to their main residence and continue to follow the government guidance on self-isolation, household isolation and social distancing.
My test was negative, can I stay?
Stay and enjoy your visit as planned but if you need medical assistance please call your own regular GP or 111.
Who to contact if you’re unwell?
How do I book a test?
Please use the address of your holiday destination.
Objective: To keep the workplace clean and prevent transmission by touching contaminated surfaces.
Steps that will usually be needed:
Policy for COVID-symptomatic guests will be on the website and we will send to the guests before they arrive, for example during the booking or check-in process.
Objective: To provide high level considerations to maintain the cleanliness of rooms.
Specific housekeeping guidance: