COVID-19 PRIVACY NOTICE
This Privacy Notice is in response to the Covid-19 pandemic. It supports the CareChoice overarching Privacy Notices and should be read in conjunction with them. Through this Privacy Notice, we have sought to be as transparent as possible and thoroughly explain how your personal data will be processed in relation to the extraordinary challenges, we are all facing during the COVID-19 pandemic.
To mitigate the spread of COVID-19 and reduce the risk of exposure to our residents, employees, external service providers and visitors you will be requested to complete a questionnaire regarding your health and social interactions to identify potential risk factors for COVID-19 infection. We will also take your temperature.
Your temperature will not be recorded other than to note whether it is below or over 37.5C. Specifically, the record will show a yes or no as to whether your temperature is equal to or greater than (≥) 37.5C.
If you answer yes to certain questions, or if your temperature is over 37.5 degrees Celsius when measured, you will be denied entry to the CareChoice facility, and you should then take appropriate action that may include returning home and contacting your GP for advice. Our screening does not constitute a diagnosis of Covid-19 or any other illness and is an infection control measure only.
We collect your name, contact details and the date of your presence in our facilitates for contact tracing purposes.
Purpose of Processing
The personal data that you provide to us in the Visitor Questionnaire will be used by us (i) to determine whether you are permitted to visit our facilities, (ii) to help us to track and address any potential exposure to COVID-19 among our residents, employees, visitors and external service providers (iii) to help to maintain the health and well-being of our residents, employees, visitors and external service contractors, and (iv) to aid service continuity.
Your Personal Data
We collect the information included on the Covid-19 Visitor Questionnaire, which includes your name, contact details and information collected to determine whether you may be displaying symptoms of Covid-19 or may have recently been exposed to Covid-19. This includes high level information about your state of health and your possible contact with Covid-19 patients. Such information will be limited to what is proportionate and necessary, considering the latest guidance issued by the Government and Public Health Authorities, to manage and contain the virus. Some of your personal data is classed as ‘special categories of personal data’ because it is information that is more sensitive and therefore requires more protection. This includes your health information.
Our Lawful Basis for Processing Your Personal Data
The legal bases on which we process your information in the manner described above are as follows:
Article 6(1)(c) – processing is necessary for compliance with a legal obligation to which the controller is subject – (this includes our obligations under the Safety, Health and Welfare at Work Act 2005 and the Infectious Disease Regulations 1981 to prevent the spread of an infectious disease).
Article 6(1)(f) – processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party.
As the personal data which you provide to us in the Questionnaire includes health data, which is a special category of data under Data Protection Law, the legal bases on which we collect and process such health data in the manner described above are as follows:
Article 9(2)(b) – processing is necessary for the purposes of carrying out the obligations and exercising the specific rights of the controller or the data subject in the field of employment and social security and social protection law And,
Section 46 of the Data Protection Act 2018 – processing of special categories of personal data for purposes of employment and social welfare law.
Article 9(2)(i) – processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to heath. And,
Section 53 of the Data Protection Act 2018 – processing of special categories of personal data for purposes of public interest in the area of public health.
Where do we get your data from?
Information is obtained directly from you through a questionnaire and from a non-invasive temperature check.
Appropriate security measures are in place to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. Access to your personal data is limited to those employees, external service providers and other third parties on a need-to-know basis. All employees are subject to a duty of confidentiality and are required to be compliant and demonstrate compliance with personal data protection.
Sharing Your Personal Data
In this current pandemic we may share your information with Public Health Authorities, Emergency Services, the HSE and Regulatory Authorities as necessary and proportionate to do or as required by law.
Retention of Data
We will retain the Questionnaires for one month after your visit to our facility after which it will be destroyed by confidential shredding unless a longer period is required by law and, if relevant, to deal with any claim or dispute that may arise.
What are my rights and how do I exercise them?
You have the right to:
- be informed of any data processing.
- access to your personal data.
- rectify your personal data.
- erase your personal data, in some circumstances.
- restrict processing of your personal data, in some applicable circumstances.
- data portability, in applicable circumstances.
- object to the processing of your personal data, in some circumstances.
- withdraw consent to the processing of your personal data, where applicable.
If you wish to exercise any of your rights, please contact the CareChoice Data Protection Officer at firstname.lastname@example.org
Questions About This Notice
If there is anything in this Notice that you are unclear about, please contact the CareChoice Data Protection Officer at email@example.com.
Should you not be satisfied with our response to your concerns or believe that we have not complied with our data protection obligations you may lodge a complaint with the Data Protection Commission at firstname.lastname@example.org.
Changes to this Privacy Notice
This Privacy Notice is kept under regular review, and we will provide you with a new Privacy Notice when we make any substantial updates.
This Privacy Notice was last updated on August 5th, 2021.