Visitor Privacy Notice for Covid-19 – England
The purpose of this Notice
This notice provides you with information about how Holmes Care Group Ltd may seek to collect and hold personal data relating to dignitaries, contractors, job applicants, suppliers, tradespeople, external training providers, regulatory bodies or other visitors to our services in relation to the Coronavirus pandemic (COVID-19). This Notice applies only to information which Holmes Care processes about you in response to the pandemic and does not affect our resident’s family members or friends who are visiting.
You may also wish to read our Vaccination Policy for more information.
About us
We are what is known as the 'controller' of personal data we gather and use. When we say 'we', 'us' or the 'Company' in this notice we mean Holmes Care Group Ltd.
In this notice:
- personal data means any information which can identify you directly or indirectly (whether itself or when combined with other data), regardless of the format or media on which the information is stored. This includes information that can identify you when combined with other information that is held separately (pseudonymous data).
- Special category data means any information which is more sensitive in nature and includes information about your health, your race, political opinions, religious beliefs, sex life or sexual orientation
- processing means any activity relating to your personal data including collection, use, alteration, storage, disclosure and destruction
What kinds of Personal Data we use in responding to the Pandemic?
Given the impact of the Pandemic, we are now required to process information about certain visitors to assess whether it is safe for them to enter the building or any of our premises. Government regulations have been introduced which require us to seek evidence from certain visitors to prove they have received the vaccine or are exempt. In order to comply with this legal obligation, we are requesting certain visitors provide us with evidence that they have had both vaccines doses, and potentially booster shots.
The evidence we require may be Special Category Data.
In complying with our obligations we may require:
- Proof you have had both vaccines
- Proof you have had a vaccine booster, if required
- Details of any medical exemption
- Outcomes of tests
- Information about your health in general
How will we collect your Personal Data?
The information will be collected directly from you.
What will we use your Personal Data for?
We are required by law to ensure that certain visitors are vaccinated. We will therefore use the information we collect for the purposes of responding to and evidencing compliance with our legal and regulatory obligations. We may also need to use your information:
- to demonstrate compliance with the law and share information with regulators such as the CQC.
- to manage and assess risk as we respond to the pandemic.
The information we collect will be limited to what is proportionate and necessary, taking into account the latest guidance issued by the Government and health professionals, in order to manage and contain the virus. It will be kept securely at all times and only seen by those who need to have access.
Lawful grounds for processing your information
We will only use your personal data where we have a lawful basis to do so under the Data Protection legislation. We will use your information where:
- It is necessary to comply with our legal obligations, for example the Health and Social Care Act 2008 (Regulated Activities) (Amendment) (Coronavirus) Regulations 2021.
- It is necessary for our legitimate interests or those of a third party, provided your rights and interests do not override those interests
Your rights
You have a right under the law regarding your personal data. Should you wish to exercise them, or if you have any concerns as to how your data is processed you can contact our Data Protection officer gdpr@holmes-care.co.uk.