Self Isolation Payment Scheme Privacy Notice
Privacy Notice for Self-Isolation Payment under the Test and Trace Support Scheme
On 28 September 2020, Government introduced a national Test and Trace Support Scheme. From 12 October 2020, a one-off payment of £500 or access to a discretionary fund will be available for eligible individuals.
Separately, and for information - pursuant to section 251 of the National Health Service Act 2006 and Regulation 3 of the Health Service (Control of Patient Information) Regulations 2002, the Department of Health and Social Care (DHSC) has special permission from the Secretary of State for Health and Social Care to use confidential patient information without people’s consent for the purposes of diagnosing, recognising trends, controlling and preventing, and monitoring and managing communicable diseases and other risks to public health. See the NHS Contact Tracing Privacy Notice.
Data Controller - The Department of Health and Social Care (DHSC) has commissioned NHS Test and Trace on behalf of the Government and is the data controller for the purposes of providing Test and Trace data to us.
Dartford Borough Council is the data controller for the purposes of assessing eligibility, administering and making payments under the Test and Trace Support Scheme.
Processing activity - if you have been told by the NHS to self-isolate, either because you have tested positive for COVID-19 or you have been in contact with someone who has tested positive, you may be entitled to some financial support ie: self-isolation payment during your self-isolation period. If you are eligible, you will receive a £500 one-off Test and Trace Support payment or provision from the discretionary fund to remain at home to help stop the spread of the virus.
Information requirements - we collect and process the personal data that you provide to us when completing your application for a self-isolation support payment, which may include:
- Full name;
- Full residential address;
- Email address;
- Mobile telephone number;
- Home telephone number;
- Proxy applicant details (as above where you may nominate someone else to complete this application on your behalf);
- Employer name and address;
- NHS notification number (the unique reference you will be given by NHS Test and Trace Service to self-isolate);
- Bank account details;
- Your National Insurance Number;
- Proof of self-employment eg: recent business bank statement (within the last two months), most recent set of accounts or evidence of self-assessment
Source of information and categories of personal data - we will obtain data from the NHS Test and Trace Service to confirm that you have either tested positive for COVID-19 or you have been in close contact with someone who has tested positive for COVID-19. As this data is related to your health, it is referred to as ‘special category data’.
You or your nominated representative may also need to provide us with additional personal data in relation to your application for a self-isolation payment.
Data Sharing - we will carry out checks with the NHS Test and Trace Service and the Department for Work and Pensions, for verification purposes, Her Majesty’s Revenue and Customs (HMRC), for tax and National Insurance purposes, and potentially, with your employer in validating your application.
Information relating to your application will also be sent to the DHSC to help understand public health implications, allow us to carry out anti-fraud checks and determine how well the test and Trace Support Scheme is performing.
We will provide information to HMRC in relation to any payments we make because self-isolation payments are subject to tax and National Insurance contributions. If you are self-employed, you will need to declare the payment on your self-assessment tax return.
If there is evidence to suggest you are not complying with the duty to self-isolate without reasonable justification, we may be asked by the Police for information, including your name, the address at which you are self-isolating, details about your self-isolation and other information the Police may need to help decide whether to investigate further.
To validate your bank account details, we need to share relevant information you have given us with TransUnion. This will be used to ensure your Test and Trace Support Payment is paid to the correct bank account and to help prevent fraudulent use of the Test and Trace Support Payment Scheme. This is not a credit check and will not impact your credit rating. For more information on how TransUnion may use your data, please visit https://www.transunion.co.uk/legal/privacy-centre
Other than as referred to above, we will not share your information with other organisations or individuals outside of Dartford Borough Council.
Our lawful bases for processing the personal data
We must have a legal basis to process your personal data. Our lawful bases in the processing that we will undertake in assessing your eligibility for, and in making any self-isolation payment to you are:
- UK GDPR Article 6(1)(c) - processing is necessary for compliance with a legal obligation pursuant to reg.3(1)(c) of the Health Service (Control of Patient Information) Regulations 2002 - controlling and preventing the spread of such diseases and risks
- UK GDPR Article 6(1)(e) – processing 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 pursuant to the Civil Contingencies Act 2004 and Civil Contingencies Act 2004 (Contingency Planning) Regulations 2005 – exercise of functions in an emergency
- UK GDPR Article 9(2)(i) – processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of healthcare;
- Data Protection Act 2018 Schedule 1 Part 1 (2) - health or social care purposes
Retention period - we keep your personal information for the minimum period necessary. The information outlined in this Privacy Notice will be kept for as long as it is needed for the purposes of the COVID-19 emergency and for audit and payment purposes, but in any event, no later than 31 December 2021. All information will be held securely and disposed of confidentially.
Right to object - where processing your personal information is required for the performance of a public interest task (see our lawful bases above), you have the right to object on ‘grounds relating to your particular situation’. We will have to demonstrate why it is appropriate for us to continue to use your personal data.
Your rights - Please refer to our Corporate Privacy Notice for further details of how we process your personal information and for details on your additional rights
Changes to this Privacy Notice - we review this Privacy Notice regularly and will place updates on our website.
Data Protection Officer - oversees compliance with the Data Protection Legislation and making sure we respect your rights and follow the law. If you have any concerns or questions about how we look after your personal information, please contact the Data Protection Officer: email@example.com
1 Note that we may process your personal information on more than one lawful basis depending on the specific purpose for which we are using your information