Coronavirus (Covid-19) employee privacy notice
This privacy notice provides you with information about how Achieving for Children may seek to collect and hold information about you in relation to the unprecedented challenges we are all facing during the Coronavirus pandemic (Covid-19).
Achieving for Children may seek to collect and process your personal data in response to the recent outbreak of Coronavirus, which is above and beyond what would ordinarily be collected from its staff and their dependents, to ensure their safety and wellbeing.
Such information 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 enable Achieving for Children to effectively fulfil its functions to keep people safe, put contingency plans into place to safeguard those vulnerable and aid business continuity. Your data will not be transferred outside of the UK for any of these purposes.
Where the information is to be used to make organisational decisions, steps will be taken to anonymise the data and general statistics/numbers used, wherever possible
Personal information we will collect about you
Personal data is being collected to enable Achieving for Children to identify:
- any staff (or those closely linked to staff/dependents) who are in any of the high-risk categories and would be considered vulnerable, if infected with Coronavirus
- the outcome of any staff testing for Coronavirus
What we are using for personal data for
- To enable us to redeploy staff to lower risk work areas if required.
- To report staff absence (self isolation, sickness, shielding etc) due to Covid-19 to national bodies such as Public Health England.
- To report staff who have tested positive for Covid-19 to the Health & Safety Executive under the RIDDOR requirements. We must make a report under RIDDOR (The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013) when:
- an unintended incident at work has led to someone’s possible or actual exposure to coronavirus.
- a worker has been diagnosed as having Covid-19 and there is reasonable evidence that it was caused by exposure at work.
- a worker dies as a result of occupational exposure to Coronavirus
Lawful basis for processing your personal data
The lawful basis for processing the data is that it is in the public interest for us to deal with the outbreak of Covid-19. The UK General Data Protection Regulation requires specific conditions to be met to ensure that the processing of personal data is lawful. These relevant conditions are below:
- UK GDPR Article 6(1)(d) – is necessary in order to protect the vital interests of the data subject or another natural person.
- UK GDPR Article 6(1)(e) – 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.
The processing of special categories of personal data, which includes data concerning a person’s health, are prohibited unless specific further conditions can be met. These further relevant conditions are below:
- UK GDPR Article 9(2)(i) – is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health.
- DPA 2018, Schedule 1, Part 1(1) – is necessary for the performance or exercising obligations or rights which are imposed or conferred by law on the controller or the data subject in connection with employment, e.g. Health and Safety at Work Act 1974.
- DPA 2018, Schedule 1, Part 1(3) – is necessary for reasons of public interest in the area of public health, and is carried out by or under the responsibility of a health professional, or by another person who in the circumstances owes a duty of confidentiality under an enactment or rule of law, e.g. Governmental guidance published by Public Health England
Who we share your personal information with
Achieving for Children will only share your personal information where the law allows, and we always aim to share the minimum data necessary to achieve the purpose required. Your personal data will be shared with:
- Line manager and members of the Workforce Development Team
- Relevant health authorities
- Central government
How long will we keep your information
Achieving for Children will only keep your information for as long as it is necessary, taking into account Government advice and the on-going risk presented by Covid-19. At a minimum the information outlined in this privacy notice will be kept for the duration of the Covid-19 response.
Information provided by staff in relation to Covid-19 will not be used for any other purpose, including to be held within personnel files ‘just in case’ it may be needed again. When the information is no longer needed for this purpose, it will be securely deleted.
Your rights and access to information
You have several rights with respect to your personal data and these remain all intact during the current coronavirus pandemic. To request a copy of your data, please read the Individual Rights Requests page on this website and then submit your request using your preferred method of contact.
If you have any questions or concerns about the way we process personal data or would like to discuss anything in this privacy notice, please contact our Data Protection Officer: firstname.lastname@example.org