On 28 September 2020, the government passed into law a national Test and Trace Support scheme. From 12 October, a one-off payment of £500 or access to a discretionary fund will be available for eligible individuals. Find more information about this scheme.

If you apply, we will need to process your personal data to assess whether you are eligible to receive financial support, and if so, to provide a payment to you. This Privacy Notice sets out what personal data we will use, how we will use it, and why we need to, when an applicant applies for this support.

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 Brighton & Hove City Council.

Brighton & Hove City Council is the data controller for the purposes of assessing eligibility, administering and making payments under the Test and Trace Support scheme.

New package to support self-isolation

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 during your self-isolation period.

What are Self-Isolation Payments?

People who are eligible 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.

Categories of personal data we collect and process

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 for example.
    • recent business bank statement (within the last two months)
    • most recent set of accounts or evidence of self-assessment

Source 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 will also provide us with additional personal data in relation to your application for a Self-Isolation Payment.

What we use your personal data for

We will carry out checks with the NHS Test and Trace Service and the Department for Work and Pensions (DWP), 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 scheme is performing.

We will not share this data with other organisations or individuals outside of Brighton & Hove City Council for any other purpose.

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.

Our lawful basis for processing the personal data

We must have a legal basis to process your personal data. Our lawful basis in the processing that we’ll undertake in assessing your eligibility for, and in making any self-isolation payment to you, is based on a legal obligation.

Where we use personal information to confirm that someone is eligible for a self-isolation payment, the sections of the law that apply are:

  • 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
  • GDPR Article 9(2)(b) – processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law
  • 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 (1) - employment, social security or social protection purposes
  • Data Protection Act 2018 Schedule 1 Part 1 (2) - health or social care purposes

Separately, we have 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.

This is known as a ‘section 251’ approval and includes, for example, using your test results if you test positive for COVID-19 to start the contact-tracing process.

The part of the law that applies here is section 251 of the National Health Service Act 2006 and Regulation 3 of the associated Health Service (Control of Patient Information) Regulations 2002.

You can find more information on this via the NHS Contact Tracing Privacy Notice.

Data Processors and other recipients of your data

These are the recipients with which your personal data is shared:

  • Her Majesty’s Revenue and Customs (HMRC) for tax and National insurance purposes;
  • Your employer for verification checks purposes;
  • IT providers who supply and support our software systems are data processors 

To validate your bank account details, we need to share relevant information you've 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 won't impact your credit rating.

For more information on how TransUnion may use your data, visit the TransUnion website.

International Data Transfers and Storage

Your information will not be processed outside of the European Economic Area.

Personal data disposal and retention

We will only keep your personal data for as long as it is needed for the purposes of the COVID-19 emergency response, and for audit and payment verification purposes.

Cookies

Cookies are small text files that are placed on your browser. To see how we use cookies, please follow this link: https://www.brighton-hove.gov.uk/about-website/how-we-use-cookies

Security

We use appropriate technical, organisational and administrative security measures to protect the information we hold in our records from loss, misuse, and unauthorised access, disclosure, alteration and destruction. We train our staff to handle information securely and we have written procedures and policies which are regularly audited at senior level. We regularly test our technology and ways of working, including keeping up to date on the latest security updates.

We will only make your information available to those who have a need to know in order to perform their Council role. We control access to systems and networks through secure log-in passwords and we can also use encryption when data is being sent, so other people cannot read it without access to an unlock key.

Automated decision making or profiling

No decision which has a significant impact on you will be made solely based on automated decision making (where a decision is taken about you using an electronic system without human involvement). 

Your rights as a data subject

By law, as a data subject you have rights under the EU General Data Protection Regulation (2016/679) and the UK Data Protection Act 2018.

All information is processed in accordance with the Brighton & Hove Council’s data protection polices.

These rights are:

  1. your right to get copies of your information – you have the right to ask for a copy of any information about you that is used.
  2. your right to get your information corrected – you have the right to ask for any information held about you that you think is inaccurate, to be corrected
  3. your right to limit how your information is used – you have the right to ask for any of the information held about you to be restricted, for example, if you think inaccurate information is being used.
  4. your right to object to your information being used – you can ask for any information held about you to not be used but if you do so it will not be possible to award you a payment. This right is not absolute. If you object after an award has been paid, we may need to continue using your information, and we will tell you if this is the case.
  5. your right to get information deleted – this is not an absolute right, and we may need to continue to use your information, and we will tell you if this is the case.

If you are unhappy about how your personal data is used as part of this programme, you should contact Brighton & Hove Council in the first instance.

If you are still not satisfied, you can contact the Information Commissioners Office. Their website address is www.ico.org.uk and their postal address is:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Data Protection Officer

If you have any question about the collection or use of your personal data you can contact our Data Protection Team on 01273 295 959 or email data.protection@brighton-hove.gov.uk.

The council also has a Data Protection Officer. Find out how to contact the Data Protection Officer.

Changes to our policy
We keep our privacy notice under regular review, and we will make new versions available on our privacy notice page on our website.