Ownership of the Personal Data

To enable the Covid-19 testing to be completed at Chipping Norton School, we need to process personal data for staff and students taking part, including sharing of personal data where we have a legal obligation.

Chipping Norton School is the Data Controller for the data required for processing the tests and undertaking any actions that are required by Chipping Norton School to ensure that we meet our public health and safeguarding legal obligations.

All data is processed under Section 3 of the Non-Maintained Schools Regulations 1999 for non-maintained schools. Data Controllership is then passed to the Department for Health & Social Care (DHSC) at the point that we transfer data to them.

Personal Data involved in the process

We use the following information to help us manage and process the tests:

• Name;
• Date of birth (and year group);
• Unique barcode assigned to each individual test and which will become the primary reference number for the tests;
• Test result;

Parent or carer contact details.

We will only use information collected directly from you specifically for the purpose of the tests, even if you have previously provided us with this information. The information will only be stored securely on local spreadsheets in school/college until it is securely shared with DHSC.

Processing of Personal Data Relating to Positive Test Results

The member of staff, student or parent (depending on contact details provided) will be informed of the result by a member of staff at Chipping Norton School and advised how to book a confirmatory test. Chipping Norton School will use this information to enact their own COVID isolation processes without telling anyone who it is that has received the positive test result.

The information will be transferred to DHSC, who will share with the National Health Service (NHS), Public Health England (PHE) and local government, who will use the information for wider test and trace activities as well as statistical and research purposes. This information is processed and shared under obligations set out in Public Health legislation under Regulations 3(1) and (4) of the Health Service (Control of Patient Information) Regulations 2002 (COPI) which allows the sharing of data for COVID related purposes. This information will be kept by Chipping Norton School for up to 14 days and by the NHS for 8 years.

Processing of Personal Data Relating to Negative Test Results

Chipping Norton School will record a negative result and the information will be transferred to DHSC, NHS, PHE and local government, who will use the information for statistical and research purposes. This information is processed and shared under obligations set out in Public Health legislation under Regulations 3(1) and (4) of the Health Service (Control of Patient Information) Regulations 2002 (COPI) which allows the sharing of data for COVID related purposes. This information will be kept by Chipping Norton School for up to 14 days and by the NHS for 8 years.

Data Sharing Partners

The personal data associated with test results will be shared with DHSC, NHS, PHE and local government to ensure they take the necessary actions they need to complete under their legal obligations.

Your Rights

Under data protection law, you have rights including:

• Your right of access – You have the right to ask us for copies of your personal information.
• Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
• Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
• Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
• You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at [email protected] if you wish to make a request.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at [email protected]. You can also complain to the ICO if you are unhappy with how we have used your data. The ICO’s address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Helpline number: 0303 123 1111

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