Test and Trace at RSC
Published 14:34 on 26 Sep 2020
We have recently registered Ripon SC with the NHS Test and Trace service so that members can scan the QR on site should they wish to. Following our registration, and subsequent words in Starboard Tack - we received some questions about how the system works and what we need to do to comply.
The NHS Test and Trace app is free to download to your smart device, you can find it in the app store. If you wish to use the app, you can scan the QR code on the posters at the club to register your presence. The club does not receive the data from NHS Test and Trace, it is stored on your own device. As we are not a hospitality venue, use of this app is not mandatory.
In addition to this app, Ripon Sailing Club has to comply with recently changes in the law to keep records of people on site. We fall under the rules as we are a 'club offering team sport activities'. The easiest and most convenient way to comply with this, for the club and for members, is to keep a report of members who have logged into the site via the new access control system - this is why we have asked you to fob your credentials on one of the readers in the course of your visit. We will keep this report available to Test and Trace for 21 days.
To be clear, no data is passed to NHS Test and Trace unless it is specifically requested by them. The club will always verify the legitimacy of any such request.
Failure to comply with the requirements of NHS Test and Trace will result in the club receiving a fine of up to £10,000.
We hope that you feel comfortable with this and if you have any further questions, please feel free to email firstname.lastname@example.org and I will do my best to answer them.
The following is the standard data processing notice for the NHS Test and Trace service,
Recording customer details: how we use your information
To support NHS Test and Trace (which is part of the Department for Health and Social Care) in England, we have been mandated by law to collect and keep a limited record of staff, customers and visitors who come onto our premises for the purpose of contact tracing.
By maintaining records of staff, customers and visitors, and sharing these with NHS Test and Trace where requested, we can help to identify people who may have been exposed to the coronavirus.
As a customer/visitor of Ripon Sailing Club you will be asked to provide some basic information and contact details. The following information will be collected:
- the names of all customers or visitors, or if it is a group of people, the name of one member of the group
- a contact phone number for each customer or visitor, or for the lead member of a group of people
- date of visit and arrival time and departure time
The venue/establishment as the data controllers for the collection of your personal data, will be responsible for compliance with data protection legislation for the period of time it holds the information. When that information is requested by the NHS Test and Trace service, the service would at this point be responsible for compliance with data protection legislation for that period of time.
The NHS Test and Trace service as part of safeguarding your personal data, has in place technical, organisational and administrative security measures to protect your personal information that it receives from the venue/establishment, that it holds from loss, misuse, and unauthorised access, disclosure, alteration and destruction.
In addition, if you only interact with one member of staff during your visit, the name of the assigned staff member will be recorded alongside your information.
NHS Test and Trace have asked us to retain this information for 21 days from the date of your visit, to enable contact tracing to be carried out by NHS Test and Trace during that period. We will only share information with NHS Test and Trace if it is specifically requested by them.
For example, if another customer at the venue reported symptoms and subsequently tested positive, NHS Test and Trace can request the log of customer details for a particular time period (for example, this may be all customers who visited on a particular day or time-band, or over a 2-day period).
We may require you to pre-book appointments for visits or to complete a form on arrival.
Under government guidance, the information we collect may include information which we would not ordinarily collect from you and which we therefore collect only for the purpose of contact tracing. Information of this type will not be used for other purposes, and NHS Test and Trace will not disclose this information to any third party unless required to do so by law (for example, as a result of receiving a court order). In addition, where the information is only collected for the purpose of contact tracing, it will be destroyed by us 21 days after the date of your visit.
However, the government guidance may also cover information that we would usually collect and hold onto as part of our ordinary dealings with you (perhaps, for example, your name, date of birth and phone number). Where this is the case, this information only will continue to be held after 21 days and we will use it as we usually would, unless and until you tell us not to.
Your information will always be stored and used in compliance with the relevant data protection legislation.
The use of your information is covered by the General Data Protection Regulations Article 6 (1) (c) a legal obligation to which we as a venue/establishment are subject to. The legal obligation to which we're subject, means that we're mandated by law, by a set of new regulations from the government, to co-operate with the NHS Test and Trace service, in order to help maintain a safe operating environment and to help fight any local outbreak of corona virus.
Ripon Sailing Club do not transfer data outside of the United Kingdom.
By law, you have a number of rights as a data subject, such as the right to be informed, the right to access information held about you and the right to rectification of any inaccurate data that we hold about you.
You have the right to request that we erase personal data about you that we hold (although this is not an absolute right).
You have the right to request that we restrict processing of personal data about you that we hold in certain circumstances.
You have the right to object to processing of personal data about you on grounds relating to your particular situation (also again this right is not absolute).
If you are unhappy or wish to complain about how your information is used, you should contact a member of staff in the first instance to resolve your issue.
If you are still not satisfied, you can complain to the Information Commissioner's Office. Their website address is www.ico.org.uk.
We keep our privacy notice under regular review, and we will make new versions available on our privacy notice page at www.ripon-sc.org.uk. This privacy notice was last updated on 16 September 2020.
Last updated 17:46 on 19 October 2020