COVID-19 symptom-free test booking system privacy notice

Kent County Council is the Data Controller for your information along with the NHS and the Department for Health and Social Care, who are also Data Controllers independent to Kent County Council. East Kent Hospitals University NHS Foundation Trust is also a data processor on behalf of Kent County Council.

This privacy notice explains how we use your personal information and your rights regarding that information

What information are we collecting?

The council will collect the following information in order to register you on the booking system:

  • first and last name
  • email address
  • phone number
  • date of birth
  • postcode.

Why are we collecting your data?

For the purpose of scheduling your appointment to attend at a testing centre to take a symptom-free coronavirus (COVID-19) test (also known as an asymptomatic test or lateral flow test).

How we will use this data?

Collected personal data is used to register you on the booking system.

The council does not use the information to verify identity of individuals, nor does it match the data we collect with your NHS medical record prior to the test.  The council does not have access to:

  • any information to identify you when you attend for the test
  • the information that you input into the NHS registration portal
  • your test result or notification that you receive from the NHS.

Please note that the council’s activity is separate to your personal information being collected by the NHS and Department of Health and Social Care.  Your personal information relating to test registration and results is processed by NHS Test and Trace.

Find out more about how the NHS Test and Trace service will use your data.

What is the legal basis for processing the data?

The council’s processing of personal data for the purposes described above is on the lawful basis of public task in Article 6(1)(e) in the General Data Protection Regulation (GDPR): processing is “necessary for the performance of a task carried out in the public interest or in the exercise of official authority”.

If we are sharing your data with others who are we sharing it with?

The council will share your data with East Kent Hospitals University NHS Foundation Trust who will be processing your personal information on behalf of Kent County Council for the purposes of booking a test.

How long is your data kept for?

We will only keep your personal data for as long as is necessary for the purposes for which we are processing it unless we are under a legal obligation or have another legitimate reason for keeping it longer.

It is not possible at this stage to estimate the duration of the pandemic or how long the council may need to keep your data. We will take account of guidance from the government to ensure a coordinated approach with other organisations.

Personal data held by the council and East Kent Hospitals University NHS Foundation Trust will be securely deleted or destroyed once we no longer have a legitimate reason to keep it.

What rights do you have in relation to our use of your data?

You have a number of rights that you may exercise in relation to your personal data. Some of the rights do not apply automatically and may not be available in certain circumstances where a lawful exception applies.

  • You have a right to access your personal data. You can request a copy of the personal data that we hold about you and ask us to explain how we use your data.
  • You have a right to object to processing of your personal data. You have an absolute right to stop your data being used for direct marketing. In other cases where the right to object applies, we may be able to continue using your data if we have a compelling reason for doing so.
  • You have a right to request the restriction or suppression of your personal data.
  • You have a right to have your personal data erased, if we no longer have a legitimate use for it. This right is sometimes called the ‘right to be forgotten’.
  • You have a right to rectification of your personal data if the information we hold in relation to you is inaccurate or incomplete.
  • You have a right not to be subject to any decision based solely on automated processing, including profiling, which produces legal or similarly significant effects. You can request human intervention or challenge any solely automated decision-making that significantly affects you.

Where can you get advice or make a complaint?

Please contact the Information Resilience and Transparency Team at data.protection@kent.gov.uk to exercise any of your rights, or if you have a complaint about why your information has been collected, how it has been used or how long we have kept it for.

You can contact our Data Protection Officer, Benjamin Watts, at dpo@kent.gov.uk, or write to: Data Protection Officer, Sessions House, Maidstone, Kent ME14 1XQ.

GDPR also gives you right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted on 03031 231113.