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Regional Contact Tracing Privacy Notice

How we use your personal information for Contact Tracing purposes within the Cwm Taf Morgannwg area.

We have summarised in this privacy notice some of the key ways in which Bridgend County Borough Council, Merthyr Tydfil County Borough Council and Rhondda Cynon Taf County Borough Council (collectively referred to as ‘we or us’ in this notice) use your personal information for Contact Tracing purposes within the Cwm Taf Morgannwg area. This information should be read in conjunction with the Council’s corporate privacy notice.

 

1.     What is Contact Tracing and how does it work?

You will be aware from the media and in particular from Welsh Government and Public Health Wales of the Test Trace Protect scheme which is key in the on-going fight against COVID-19 (Corona virus) and helping to find a way for people in Wales to live and work alongside the virus whilst containing its spread.

Contact tracing is a known method of controlling the spread of an infectious disease, it is not about surveillance or enforcement but about protecting people’s health.  As soon you start to display symptoms you should arrange to take a test as quickly as possible, whilst you and members of your household self-isolate.

As lockdown restrictions are slowly relaxed, we will all need to take steps to protect ourselves, families and the community.  Contact tracing plays an important role in helping us resume day-to-day activities.

It must be noted that during this challenging and unusual time of dealing with the Coronavirus pandemic, each of the Council’s has to very quickly change the way in which they are working to continue to provide you with the support and services you need.  We will always follow advice and guidance from the Welsh Government and Public Health Wales and any changes to the way in which we provide you with that support with regards to Test, Trace, Protect will be updated within this privacy notice.

 

2.     Who provides Contact Tracing?

Public Health Wales, Welsh Government, NHS Wales and all Council’s in Wales are working together to provide the Test, Trace, Protect Service. The following outlines what each organisation does in relation to Contact Tracing.

 

 

Regional Contact Tracing Teams 

For the Cwm Taf Morgannwg area;Bridgend County Borough Council, Merthyr Tydfil County Borough Council and Rhondda Cynon Taf County Borough Council are working together to deliver Contact Tracing for people who live within these counties.   

The regional Contact Tracing Team will contact individuals who have received a positive test to discuss their symptoms and establish who they have been in contact with (referred to as ‘contacts’) and when.

The team will also make contact with the contacts on a daily basis to see if they are experiencing any symptoms and to offer advice and guidance on self-isolating.

All calls made by the Contact Tracing teams are recorded for monitoring/training purposes and to assist with resolving any complaints that maybe received. 

 

NHS – Cwm Taf Morgannwg University Health Board

For residents who have been in hospital for more than 3 days, you will be classed as a ‘hospital acquired covid case’ and the Local Health Board will undertake Contact Tracing on behalf of the Local Authority.

Your details will be passed to the hospital’s Infection Prevention and Control team (IP&C) who will contact/meet with you to undertake the contact tracing questions. 

This will be the same process for someone who has been discharged from hospital, but soon after discharge, tests positive for Covid, the IP&C Team will contact you to discuss your symptoms and who you have been in contact with.

If you would like further information on how Cwm Taf Morgannwg University Health Board handles your personal information, please visit; https://cwmtafmorgannwg.wales/privacy-statement-for-patient-information/

 

NHS – NHS Wales Informatics Service (NWIS)

NWIS are providing the digital system in which all information captured by the regional Contact Tracing teams are securely stored.  

If you would like further information on how NWIS handles your personal information, please visit; https://nwis.nhs.wales/use-of-site/privacy-policy/

 

Public Health Wales (PHW)

Public Health Wales are providing specialist support, advice and leadership at a national level to NHS Wales, Local health Boards and Local Authorities in relation to COVID.  

If you would like further information on how Public Health Wales handles your personal information, please visit; https://phw.nhs.wales/use-of-site/privacy-notice/

 

3.     What and whose personal information we hold?

 The Contact Tracing Team will hold the following information about the following people:

Individual who has tested positive for COVID-19:

  • Full name
  • Full address and contact information such as your telephone number and email.
  • Date of birth
  • Sex
  • NHS number
  • Details on COVID-19 test information such as test date, result date, result (positive)
  • Details on COVID-19 symptoms
  • Information about whether you are in a care home or hospital.
  • Information about whether you are a Shielded Patient and the reason why.
  • Disability and ethnicity data
  • Details of your household and living arrangements.
  • Information about the people you have been in contact with, this may include household members, family, friends and colleagues etc.  
  • Information about the places you have visited.
  • If you have been in contact with colleagues we may also need information about your place of work and employment.
  • Any other information that may be relevant to contact tracing that you may wish to share with us.
  • A record of any advice and information we have given you.

Individual who has been in contact with a person who has tested positive for COVID-19:

  • Full name
  • Full address and contact information such as your telephone number and email.
  • DOB
  • Details on any COVID-19 symptoms you may be experiencing.
  • Disability and ethnicity data.
  • A record of any advice and information we have given you.
  • Any other information that may be relevant to contact tracing that you may wish to share with us.

If you are aged 16 and over you can give permission for us to speak to someone else on our behalf.  If you are under the age of 16 we will speak to your parents/guardians about your symptoms. 

 

4.     Where does the service get my information from?

Individual who has tested positive for COVID-19:

  • If you have tested positive for COVID-19 your information will be passed to the Tracing Team by the NHS/Cwm Taf Morgannwg University Health Board.
  • The Tracing Team will also gather more information directly from you when they speak to you and you agree to answer questions from the Contact Tracer.

Individual who has been in contact with a person who has tested positive for COVID-19:

 

  • If you have been identified as being in contact with someone who has tested positive for COVID-19, your name and contact details will have been provided to us by the individual who has tested positive (please note for confidentiality reasons we will not able to tell you who that person was).
  • The Tracing Team will also gather more information directly from you when they speak to you and you agree to answer questions from the Contact Advisor.

 

Permission to act on your behalf:

If you are aged 16 and over you can give permission for us to speak to someone else on our behalf if you prefer.

If you are under the age of 16 we will speak to your parents/guardians about your symptoms. 

 

5.     What will we do with your personal information?

Individual who has tested positive for COVID-19:

If we have been notified that you have tested positive, one of the Contact tracers will contact you to provide advice and support, they will ask about your symptoms and try to establish who you have been in contact with. 

It may be necessary for us to refer your case to other departments in the Council, for example Social Services if we have any safeguarding concerns about your welfare or others within your home.  Officers have a legal duty to this and if you would like to know more about why and how we will do this please take a look at our Community & Children Services privacy notice.

Individual who has been in contact with a person who has tested positive for COVID-19:

If you have been in contact with someone who has tested positive, an Advisor will make contact with you and if you agree to answer the questions they will provide you with advice on what to do next, for example how long you need to isolate for. 

You will also receive daily wellbeing calls to see how you are doing and, if you develop symptoms, you will be advised to book a test and how to do this.

If you do not engage with the team and do not want to answer any questions, we are required to send you a letter explaining what action you need to take. 

 

Research & Reporting

Analysis of the above information may also be used by us, the NHS, Public Health and Welsh Government to produce reports that will;

  • Understanding COVID-19 and risks to public health, trends in COVID-19 and such risks, and controlling and preventing the spread of COVID-19 and such risks
  • Identifying and understanding information about patients or potential patients with or at risk of COVID-19
  • Delivering services to patients, clinicians, the health services to our citizens.
  • Research and planning in relation to COVID-19 (including potentially being invited to be part of clinical trials)
  • Monitoring the progress and development of COVID-19.

 

6.     What is the legal basis for the use of this information?

 The legal basis for processing your personal data for contract tracing purposes under the General Data Protection Regulation (GDPR) is:

  • Article 6(1)(e) – Task carried out in the public interest or in the exercise of official authority vested in the controller

For more sensitive data such as health information (known as special category data) an additional legal basis is required and is:

  • Article 9(2)(i) - Processing must be 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 health care and of medicinal products or medical devices)

This is supported by the following legislation:

  • Public Health (Control of Diseases) Act 1984
  • The Health Protection (Wales) Regulations 2010
  • The Health Protection (Notifications)(Wales) Regulations 2010
  • The Health Protection (Local Authority Powers) (Wales) Regulations 2010
  • The Coronavirus Act 2020
  • The Health Protection (Coronavirus Restrictions)(Wales) Regulations 2020
  • The Health Service (Control of Patient Information) Regulations 2002

 

7.     Does the service share my personal information with any other organisation?

 

All of the information provided to and recorded by us will be securely stored in the customer record management system. This system is managed by the NHS Wales Informatics Service (NWIS) on our behalf.

NHS Wales Health Boards & Trusts and Public Health Wales will have access to this system and may use your data for the purposes outlined section 6 of this notice.

 

8.     How long will my information be kept?

 We will only keep your personal data for as long as is necessary and for the purpose for which we are processing it. 

For an individual who has tested positive for COVID-19 this will be for 7 years.

For an individual who has been in contact with someone who has tested positive, but does not have any symptoms themselves, we will keep your records for 5 years.

 

9.     Your information, your rights

 The General Data Protection Regulation (GDPR) gives you important rights, including the right to access the personal information the services hold about you.

Click here for further information on your information rights and how to exercise them. 

 

10. Contact us

If you have any concerns or would like to know more about how your personal information is being used for Contact Tracing purposes please contact us at:

 

Rhondda Cynon Taf Borough Council

Public Health Team

Ty Elai,

Dinas Isaf East,

Williamstown,

Tonypandy,

RCT

CF40 1NY

 

By email : ContactTracingServiceRCT@rctcbc.gov.uk

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