COVID-19 (CORONAVIRUS) PRIVACY NOTICE
This Privacy Notice is in response to the Covid-19 (Coronavirus) pandemic. It supports the CareChoice overarching Privacy Notices to explain how we will collect, use, and protect personal data in relation to the extraordinary challenges we are all facing during the COVID-19 (Coronavirus) pandemic.
The CareChoice Group already holds data regarding residents, employees, and other individuals. You may have provided this information for a specific reason. Normally, the CareChoice Group would seek to inform you that the data provided would be used for a different purpose. However, due to the rapidly emerging situation regarding the current pandemic this will not always be possible.
Monitoring the COVID-19 situation necessitates the processing of more health data relating to residents, employees, and other individuals. We may in this current crisis need to ask you for personal information including sensitive personal information.
Your Personal Data
The CareChoice Group is taking the necessary steps to contain the spread and mitigate the effects of COVID-19 in accordance with the guidance of the Public Health Authorities and the Government. Many of these steps will involve the processing of personal data. This may for example entail taking your temperature, asking whether you are part of an ‘at risk group’, information about your symptoms, whether you or a close contact has been exposed to a known case of COVID-19, if you are or need to self-isolate and the length of time you self-isolate. It may also include the processing of your name, address, phone number, email address, workplace details, travel details, details of absence from work and the reason for same. Some of your personal data is classed as ‘special categories of personal data’ because it is the information that is considered to be more sensitive and therefore requires more protection. This includes your health information including results of testing for COVID-19 and other health related data.
Such information will be limited to what is proportionate and necessary, taking into account the latest guidance issued by the Government and Public Health Authorities, to manage and contain the virus.
Our Lawful Basis for Processing Your Personal Data
The General Data Protection Regulation requires specific conditions to be met to ensure that the processing of personal data is lawful. These relevant conditions are below:
- Article 6(1)(d) – processing is necessary in order to protect the vital interests of the data subject or another natural person.
- Article 6(1)(c) – processing is necessary for compliance with a legal obligation to which the controller is subjectEmployers also have a legal obligation to protect their employees under the Safety, Health and Welfare at Work Act 2005 (as amended)
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. These further relevant conditions are below:
- 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 health.
- 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.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. We limit access to your personal data to those employees, contractors and other third parties on a need-to-know basis.
All employees are subject to a duty of confidentiality, and they 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 (Community Health Organisation) and other stakeholders as necessary and proportionate to do.
Retention of Data
We will only keep your information for as long as it necessary, considering the advice of Government and the Public Health Authorities and the on-going risk presented by COVID-19.
When the information is no longer needed for this purpose, it will be securely deleted.
Questions About This Notice
If there is anything in this notice that you are unclear about, please contact the CareChoice Group Data Protection Officer at firstname.lastname@example.org.
The Data Protection Officer will answer any queries you may have concerning this Privacy Notice or the way in which we process your personal data.
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 email@example.com.
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 published on May 14th, 2020.