Any questions relating to Data Privacy with ICTL or this Policy should be sent by email to email@example.com or by writing to The Data Protection Officer, Instant Covid Test London Chiswell Street London EC1Y 4SD.
Alternatively, you can call The Data Protection Officer on 0207 065 5736.
What personal Information is collected
We may collect and process the following data from you:
• Information you explicitly consent to provide ICTL that is required to carry out our obligations arising from any contracts entered between you and us (i.e. special category data required for Covid-19 testing purposes), or potential contracts that may be in liaison between you and us.
This includes and is not limited to personal information about you such as your name, telephone contact number, geographical address/location, email address, special categories of personal data required as part of the testing and track and trace activities.
Clear unambiguous consent information is supplied at point of collection to provide information on the use of data; and a record of the consent is taken at point of collection.
• If you contact us by telephone or in writing, we may keep a copy of your correspondence or communication.
If you have provided us with the personal data of another person, there is a clear requirement imposed by ICTL for you to confirm that he/she consents to the processing of his/her personal data and that you have informed him/her of our identity as a Data Controller and the nature of the processing taking place. Records will be retained as evidence of this consent.
Legal basis for processing your personal data
The following legal basis are used when undertaking processing activities within ICTL:
Data Subject Covid Testing – Individual Data Subjects
When entering into a contract with us for an instant Covid test you are required to provide us with certain personal data to include some special category personal data. This data is required in order for us to carry out the initial testing, undertake identification verification on the day of test, and to also support any regulatory reporting activities to Public Health England as part of the national Track and Trace system.
As ICTL are providing a contracted (paid for) service to the Data Subject for Covid-19 Testing, the legal basis is noted as:
Article 6 (b) Contract: the processing is necessary for a contract ICTL has with the individual.
With the supporting legal basis for Special Category data noted as
Article 9(2)(a) Explicit Consent – The data subject has given explicit consent to the processing of those personal data for one or more specified purposes
Other Processing Activities (Commercial)
Article 6 (f) Legitimate Interests – We use information held about you to provide you with information, products and/or services that you request from us or which we feel may interest you if relevant to the products or services currently being supplied as part of a contract with ICTL, or in relation to a previous contract with ICTL whereby you are happy to continue to receive such information;
Article 6 (b) Performance of a contract – We use information held about you to carry out our obligations arising from any contracts entered into between you and us; and to notify you about changes to our services.
Article 6(1)(c) (legal obligation): the Health Protection (Notification) Regulations 2010 require the reporting of positive, negative and void test results to the Public Health Authorities, in this case, Public Health England.
What information is held about you, and by whom?
ICTL – ICTL do not hold any personal data for individuals but they may be given access by System Bookings to your name, email address and phone number to contact you in the event of cancellation or rescheduling of the booked test. ICTL will only hold data for corporate companies who sign a contract with us, and that would be commercial data. Any personal data of individuals who wish to take tests would be uploaded by their companies into Systembookings.com directly, without ICTL involvement. If you email or phone ICTL to send feedback or a comment, your details will be used to investigate the complaint or address the feedback and contact you back if necessary.
Systemsbooking.com – Provide the technical support to process your Covid-19 test booking and supply you with your unique QR code for the test, appointment reminders, email or SMS with a link to a third party review website, and to send you your results and certificate. Systembooking.com will also forward details of all test results to Public Health England daily as part of the National Track and trace system. Systems booking hold the following information; Full Name, Home address, Current residence (if not home address), Phone Number, Date of birth, Sex, Ethnicity
Public Health England – PHE is an executive agency, sponsored by the Department of Health and Social Care. Support the NHS Track and Trace activities. PHE with receive the following personal data about you – Full Name, Home address, Phone Number, Current residence (if not home address), Date of birth, Sex, Ethnicity
Payment Facility Providers (Stripe) – Payment details will be shared with our secure payment facility providers for ongoing travel (if required)
ICTL Covid-19 Test Staff – Limited special category data may be disclosed (visually only) to trained ICTL testing support staff for the purposes of identification verification and processing of test results.
As part of our GDPR compliance obligations, we are duty bound to check when personal data may be shared with third parties to ensure that they apply the same or greater controls in terms of data protection. The use of non-disclosure agreements form part of our third-party data sharing controls.
Non special Category Data – Staff and Corporate clients
We may disclose your personal information to any member of our group, which means our subsidiaries, strategic partner(s) or strategic sponsor(s) our ultimate holding company and its subsidiaries as defined in section 1159 of the UK Companies Act 2006.
We may disclose your personal information to third parties
• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
• if we or substantially all of our assets are acquired by a third party, in which case personal data held by it about our customers will be one of the transferred assets; or
• to protect the rights, property or safety of ICTL, our customers or others.
From time to time, our website may contain links to and from our strategic partner(s), partner network(s), strategic sponsor(s), advertiser(s) and affiliate(s). If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.
To download Instant Covid Tests London’s data protection impact assessment please click here