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  • Privacy
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  • Recording Premises Visitor Details for NHS Test and Trace
  • Recording Premises Visitor Details for NHS Test and Trace

    The purposes of the processing
    Personal data we collect
    Sensitive (special category) personal data we collect
    Who we are
    The contact details of our data protection officer
    The lawful basis for processing personal data
    The lawful basis for processing special category personal data
    Relevant legislation
    The legitimate interests for the processing
    Who we share your data with
    Transfers of personal data to any third countries or international organisations
    How long we keep your personal data
    Your rights
    Your right to withdraw consent
    Mailing list
    Your obligation to provide the personal data
    The existence of automated decision-making, including profiling
    Your right to lodge a complaint with a supervisory authority


    The purposes of the processing

    To support NHS Test and Trace (which is part of the Department for Health and Social Care) in England, Hastings Borough Council has decided to collect and keep a limited record of staff, customers and visitors who come onto our premises for the purpose of contact tracing.

    By maintaining records of staff, customers and visitors, and sharing these with NHS Test and Trace where requested, we can help to identify people who may have been exposed to the Coronavirus.

    As a customer/visitor of Hastings Borough Council you will be asked to provide some basic information and contact details. The following information will be collected:

    • The names of all customers or visitors, or if it is a group of people, the name of one member of the group.
    • A contact phone number for each customer or visitor, or for the lead member of a group of people.
    • Date of visit and arrival and departure time.

    In addition, if you only interact with one member of staff during your visit, the name of the assigned staff member will be recorded alongside your information.

    NHS Test and Trace have asked us to retain this information for 21 days from the date of your visit, to enable contact tracing to be carried out by them during that period. We will only share information with NHS Test and Trace if it is specifically requested by them. For example, if another customer at the venue reported symptoms and subsequently tested positive, NHS Test and Trace can request the log of customer details for a particular time period (e.g. this may be all customers who visited on a particular day or time-band, or over a two-day period).

    Under government guidance, the information we collect may include information which we would not ordinarily collect from you and which we therefore collect only for the purpose of contact tracing.  Information of this type will not be used for other purposes (such as surveillance of an individual's movements or marketing activities), and NHS Test and Trace will not disclose this information to any third party unless required to do so by law (e.g. as a result of receiving a court order). In addition, where the information is only collected for the purpose of contact tracing it will be destroyed by us 21 days after the date of your visit.

    If you do not wish your contact information to be passed to NHS Test and Trace if requested, please let us know when we request your details.

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    Personal data we collect

    • Names
    • Phone numbers
    • Date and time of visits

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    Sensitive (special category) personal data we collect

    None.

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    Who we are

    Hastings Borough Council
    Muriel Matters House
    Hastings
    East Sussex
    TN34 3UY

    Tel:  01424 451066

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    The contact details of our data protection officer

    Data Protection Officer
    Hastings Borough Council
    Muriel Matters House
    Hastings
    East Sussex
    TN34 3UY

    Contact our data protection officer.

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    The lawful basis for processing personal data

    Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect the individual's personal data which overrides those legitimate interests.

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    The lawful basis for processing special category personal data

    Not applicable.

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    Relevant legislation 

    Not applicable. 

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    The legitimate interests for the processing

    The legitimate interest in this case is the interest of Hastings Borough Council in co-operating with NHS Test and Trace in order to help maintain a safe operating environment and to help fight any local outbreak of coronavirus.

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    Who we share your data with

    Your details may be shared with NHS Test and Trace.

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    Transfers of personal data to any third countries or international organisations

    Any contracts with providers who might host personal information abroad have appropriate clauses to ensure adequate technical and organisational security measures are in place.

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    How long we keep your personal data

    Your personal data will be stored for 21 days.

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    Your rights

    You can find out more about each of your rights on our Your privacy page.      

    You can ask for access to the information we hold on you.

    You can ask to change information you think is inaccurate.

    You can ask to limit what we use your personal data for.

    You can object to us processing your personal data.

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    Your right to withdraw consent

    Not applicable.

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    Mailing list 

    Not applicable.

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    Your obligation to provide the personal data

    You are not obliged to provide your personal data.

    However, If you do not supply your personal data, we will not be able to pass it to NHS Test and Trace.

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    The existence of automated decision-making, including profiling

    Not applicable.

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    Your right to lodge a complaint with a supervisory authority

    The Information Commissioner is the UK's independent body set up to uphold information rights.

    If you would like to know more about your rights under the Data Protection law, and what you should expect from us, visit the Information Commissioner's website.

    If you have any concerns regarding our privacy practices or about exercising your Data Protection rights, you may contact the Information Commissioner's Office:

    Information Commissioner's Office
    Wycliffe House
    Water Lane
    Wilmslow
    Cheshire
    SK9 5AF

    Tel: 0303 123 1113 or 01625 545 745
    Email: casework@ico.org.uk

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