Coronavirus (COVID-19) privacy notice
1 Council Contact Details
1.1 West Northamptonshire Council
One Angel Square
West Northamptonshire Council is committed to protecting your privacy when you use our services. This Privacy Notice explains how we use information about you in relation to the current pandemic (COVID-19) and how we protect your privacy.
The organisation collects and processes personal data relating to our customers, partners and staff. The organisation is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
2 Information that we hold
2.1 The Council already holds data on our customers, most of which is provided to us directly by you.
We may, in this current pandemic, need to ask you for personal data, including sensitive personal data, that you have not already supplied - for example, your age or if you have any underlying health conditions or are vulnerable or if you are displaying Covid symptoms such as a cough and a high temperature or if you have been confirmed as testing positive for the virus. This is so the Council can assist you and prioritise its services and keep you and our employees safe.
We may also need to ask for more detail than usual in business situations, which for sole traders may be classed as more sensitive personal information, like bank details or other data we don’t normally hold.
If you are volunteering to provide support services we may need your contact information, and details of your current health status to protect you, and our customers.
The types of data we may process, (including collection and sharing of those we don’t already hold) in the current crisis include:
- contact details (phone number, email address and so on)
- date of birth
- payment information (for example, bank account details for payment of business grants)
- any information which could be used to identify people who are vulnerable to the virus or otherwise require support due to the virus (health information)
- any information which illustrates a person’s needs (health information)
- any information which may indicate that a person has symptoms or has tested positive for the virus
The council recognise that the last three categories of personal data are classed as special category data and as such additional safeguards are in place for processing this type of data.
Covid-19 High Risk Groups
Personal data is being collected to assess and provide support to adults, children and young people who are in high-risk categories and would be considered vulnerable, if infected with Covid-19 (coronavirus).
3 How the information is obtained
3.1 Most of the personal information we process is provided to us directly by you
3.2 Why does the organisation process my personal data?
We are obliged by law to process your personal data during the current pandemic under The Health Service (Control of Patient Information) Regulations 2002 r3(4), the Coronavirus (COVID-19): notification to organisations to share information, and The Civil Contingencies Act 2004. We are also are enabled to carry out our statutory functions under The Civil Contingencies Act 2004, and the Local Government Act 1972 s139.
Where we are collecting or processing your special category data we need to do this for reasons of public health protection under GDPR Article 9(2) (i).
4 What we do with the information
4.1 The data we are processing is being used to:
- prevent or mitigate the impact of the virus
- record and identify people who may be vulnerable to the virus or otherwise require support due to the virus
- keep our resident and our employees safe
- share information with other organisations to allow them to help people who need it
- process payments you make to us to allow us to go shopping for you
- record details of volunteers who are willing to help us
- share details of volunteers with other organisations to help with resourcing
- process donations made to us because of the virus
- publish information about your donations if you give us your consent
- share information with other organisations who are allowed to process confidential patient information in relation to Covid-19 purposes as defined by the Secretary of State
4.2 Who has access to data?
Where we already hold, or are now collecting, your personal information regarding vulnerability as defined in the current guidance from the Government and Public Health England, we may share this with services both inside and outside the Council including sharing with Public Health England. We will only share the minimum data necessary in all circumstances.
4.3 Automated decision-making is where decisions are made about you without any human influence on the outcome. These may affect your legal rights or have an impact on your circumstances, behaviour or choices.
4.4 Profiling is where you analyse parts of an individual’s personality, behaviour, interests and habits to identify their preferences, make predictions or decisions about them.
5 How long we keep your information for and how we securely dispose of it after use
5.1 How we keep your information safe
The organisation takes the security of your data seriously. Please refer to the organisations’ main privacy statement regarding keeping your information safe.
Where the organisation engages third parties to process personal data on its behalf, they do so on the basis of written instructions. They are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data and that they meet the requirements of the current data protection legislation.
Similarly where we provide information to other organisations to support you, they do so in line with strict data sharing protocols to keep your information safe.
How long do we keep your data?
The organisation will not hold any personal data collected and processed specifically for the purposes of the current pandemic for any longer than is absolutely necessary.
The periods for which any data we hold for other purposes (which may be currently being processed to support work around the pandemic) are set out in the council’s retention schedules.
5.2 We will securely dispose of your information in line with retention periods.
6 How we store your information
6.1 Data is stored securely in the Council's IT systems. Access to data collected or shared for the purposes of responding to the current pandemic and ensuring services are provided to you is limited only to those who need to be able to process it.
7 Your data protection rights
7.1 The law gives you a number of rights to control what personal information is used by us and how we can use it. Please see section 15 of the council’s Corporate Privacy Notice for further information.
7.2 Please be aware that your rights may differ depending on the lawful basis for processing your personal data.
7.3 The right to withdraw consent (if applicable). You can ask that we no longer use your details for this [processing/groups of processing]. If you wish to exercise this right, please contact the Data Protection Officer detailed in section 8.1 below.
8 Who to contact
8.1 If you would like further information about how we use your personal information, or you wish to exercise one of your data rights or you wish to complain about the use of your personal information please contact the Data Protection Officer.
8.2 If you are still dissatisfied once you have contacted the Data Protection Officer, you have the right to complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Helpline number: 0303 123 1113
You have a right to approach the Information Commissioner’s Office regarding your Information Rights at any time. Please visit Information Commissioner's Office website.
Completion and review dates
This privacy notice was completed on 26 March 2021
The privacy notice review date is March 2022