Test and Trace Support Payments
On 28th September 2020, the Government passed into law a national Test and Trace Support scheme. From 12th October, a one-off payment of £500 or access to a discretionary fund will be available for eligible individuals. More information about this scheme can be found here.
If you apply, we will need to process your personal data to assess whether you are eligible to receive financial support, and if so, to provide a payment to you. This Privacy Notice sets out what personal data we will use, how we will use it, and why we need to, when an applicant applies for this support.
The Department of Health and Social Care (DHSC) has commissioned NHS Test and Trace on behalf of the government and is the data controller for the purposes of providing Test and Trace data to East Northamptonshire Council.
East Northamptonshire Council is the data controller for the purposes of assessing eligibility, administering and making payments under the Test and Trace Support scheme.
Your personal information – what we need and why
The controllers collect and process your personal information that you provide to us when completing your application for a self isolation payment.
We will obtain data from the NHS Test and Trace Service to confirm that you have either tested positive for COVID-19 or you have been in close contact with someone who has tested positive for COVID-19. As this data is related to your health it is referred to as ‘special category data’.
You or your nominated representative will also provide us with your personal data in relation to your application for a Self-Isolation Payment.
The types of personal data we will collect include:
- Your name and address
- Contact details
- Proxy details (if you nominate someone else to complete the application on your behalf)
- Employer details
- NHS Notification number (a unique reference provided by NHS Test and Trace when you are asked to self isolate)
- Bank account details (for the payment to be made)
- Your national insurance number
- Proof of self employment (eg a recent business bank statement from within the last two months/your most recent set of accounts/evidence of self assessment)
We will not collect any personal data from you that we do not need.
We must have a legal basis to process your personal data. Our lawful basis in the processing that we’ll undertake in assessing your eligibility for, and in making any self-isolation payment to you, is based on a statutory duty.
Where we use personal information to confirm that someone is eligible for a self-isolation payment, the sections of the law that apply are:
- GDPR Article 6(1)(e) – processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
- GDPR 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 or ensuring high standards of quality and safety of healthcare;
- Data Protection Act 2018 Schedule 1 Part 1 (3) - health or social care purposes
Separately, we have special permission from the Secretary of State for Health and Social Care to use confidential patient information without people’s consent for the purposes of diagnosing, recognising trends, controlling and preventing, and monitoring and managing communicable diseases and other risks to public health.
This is known as a ‘section 251’ approval and includes, for example, using your test results if you test positive for COVID-19 to start the contact-tracing process.
The part of the law that applies here is section 251 of the National Health Service Act 2006 and Regulation 3 of the associated Health Service (Control of Patient Information) Regulations 2002.
You can find more information on this via the NHS Contact Tracing Privacy Notice here.
How we keep your information safe.
We use appropriate technical, organisational and administrative security measures to protect any information we hold in our records from loss, misuse, and unauthorised access, disclosure, alteration and destruction.
Who do we share your data with?
We will carry out checks with the following organisations:
- the NHS Test and Trace Service and the Department for Work and Pensions (DWP), for verification purposes;
- Her Majesty’s Revenue and Customs (HMRC), for tax and National Insurance purposes; and
- potentially with your employer in validating your application.
Information relating to your application will also be sent to the DHSC to help understand public health implications, allow us to carry out anti-fraud checks and determine how well the scheme is performing.
We will not share this data with any other organisations or individuals outside of East Northamptonshire Council for any other purpose unless the law expressly allows them to.
How long do we keep your data?
We will keep your personal information only for as long as it is needed for the purposes of the COVID-19 emergency and for audit and payment purposes, after which time it will be securely destroyed.
International Data Transfers and Storage
No data related to this privacy notices is stored or transferred outside of the EEA by East Northamptonshire Council.
Automated decision making or profiling
No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
Changes to our policy
We keep our privacy notice under regular review, and we will make new versions available on our privacy notice page on our website. This privacy notice was last updated on 9 October 2020.
Your Data Rights
If you are unhappy with the use of your personal data or for further information please contact the council’s Data Protection Officer. You may also contact them in writing at East Northamptonshire Council, Cedar Drive, Thrapston, Northamptonshire, NN14 4LZ or by phone on 01832 742229.
If you are still not satisfied you can complain the Information Commissioners Office at www.ico.org.uk or by post to Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
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