0 Items

COVID -19 Test – Fair Processing Notice

This information supplements, and should be read in conjunction with, the information made available on our “Privacy Policy” (which can be found at https://circular1.com/privacy-policy/).

Your personal information will be treated in a secure and confidential manner and only as detailed in this notice and the information made available on our Privacy Policy.

Please do not hesitate to contact our Data Protection Officer at [email protected] if you have any queries.

What processing activities do you undertake that include my personal information?

We will primarily process your personal information to ensure that you can be Tested for COVID-19 and notified of the result along with reminders for upcoming test dates. We are legally obliged to report all test results to PHE. We may need to undertake further processing of your information (and seek further information from you in the event you Test positive – see categories below).

What categories of personal information are included in these processing activities?

To perform our Services, we need to collect and process the information requested on the Testing Request Form. We also process information related to the COVID-19 Tests, including the Test results. This may include health information, a special category of personal information. If you Test positive, we may require more information from you, including current address, current residence (if different), ethnicity and NHS number that will be provided to Public Health England.

What is the reason for these processing activities?

We undertake this activity to perform our Services and to comply with our legal and reporting obligations under applicable law.

What are the legal grounds you rely on to carry these out?

  • This processing is also necessary for the purpose of the legitimate interests pursued by us in the performance of our Services.
  • To help us comply with our legal obligations to retain certain records about the handling of any Covid test sample you send us for regulatory purposes. To fulfil any applicable legal and regulatory requirements, for example regulatory reporting obligations to health agencies, or retaining certain tax and accounting records for financial reporting.

What are the ‘legitimate interests’ referred to above?

It is in our legitimate interests to process your personal information in order to perform our Services, as we need to ensure that our Tests and notification service can be carried out in a way that can be properly attributed to you on our internal systems and so that we can report the Test results and test reminders to you, our Client and/or Public Health England.

As this processing may include special categories of personal information or information relating to health, in addition to the above, what are the additional legal grounds you rely on?

This processing is needed for carrying out preventative or occupational medicine testing Services, to meet public interests in the area of public health, to meet our reporting obligations under applicable law (such as our obligation to report Test results to Public Health England) and for research and statistical purposes.

How did you collect this information?

Your personal information necessary to conduct our Services will initially be collected directly from you for this purpose. If you test positive, we may require further information from you – see categories above.

Who do you share this personal information with?

Your personal information is shared with our Client. In addition, some of your personal information may be shared within our Group and with selected external service providers as needed to carry out the Tests and send out Reminder notifications. (Further details of these can be found in our Privacy Policy detailed below). We also have a legal obligation to report all Test results to Public Health England.

How long do you retain data relating to Covid-19?

We will retain your personal information for as long as is reasonably necessary.

Your rights

  • This processing is also necessary for the purpose of the legitimate interests pursued by us in the performance of our Services.
  • To help us comply with our legal obligations to retain certain records about the handling of any Covid test sample you sendus for regulatory purposes. To fulfil any applicable legal and regulatory requirements, for example regulatory reporting obligations to health agencies, or retaining certain tax and accounting records for financial reporting.

Please refer to our Privacy Policy at https://circular1.com/privacy-policy/ or contact our Data Protection Officer for further details.