Circular 1 Health Ltd.

COVID-19 Test – Fair Processing Notice

In the wake of the global Covid-19 pandemic, Circular 1 Health is providing testing processes. To run the testing programme it will be necessary to process your personal data. We set out below information regarding how we will use your information collected for this purpose.

This information supplements, and should be read in conjunction with, the information made available on our “Privacy Policy” (which can be found at

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 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 will also process your information to provide Fight Certificates for travel and Test to Fly services if required.

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 this portal.

We also process information related to the COVID-19 Tests, including the Test results. This may include health information and special categories of personal information, including medical results and ethnicity (both are required for the reporting to PHE).. Special category information will always be processed according to UK GDPR regulations.

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 fulfill 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 to you, our Client and/or your public health authority (i.e. 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.

Also, as this is sensitive medical information, we use the following legal grounds under Article 9 GDPR and Schedule 1 DPA2018:

Where the data subject has given their explicit consent or it is necessary for the purposes of preventive or occupational medicine, medical diagnosis, or the provision of health care or treatment.

How did you collect this information?

Your personal information necessary to conduct our Services will initially be collected directly from you for this purpose.

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). Your personal information is also shared within our Group and with selected external service providers as needed to carry out the Tests. (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 your Public Health Authority.

Your rights

Please refer to our Privacy Policy at or contact our Data Protection Officer for further details.

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