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, DHSC has provided guidance which we have chosen to follow. The guidance recommends that we 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 coronavirus.
As a customer or visitor of Mills Chody LLP you might be asked to provide some basic information and contact details. The following information will be collected:
• the names of all customers or visitors
• a contact phone number for each customer or visitor
• date of visit
The venue or 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. If 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. NHS Test and Trace 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 or 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 as part of its guidance, has recommended that we 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 other customers at the venue subsequently tested positive, NHS Test and Trace can request the log of customer, visitor and staff details on a particular day.
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 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 UK General Data Protection Regulations Article 6 (1) (f) – legitimate interests of the venue or establishment. The legitimate interest in this case is the interest of the venue/establishment in co-operating with NHS Test and Trace in order to help maintain a safe operating environment and to help fight any local outbreak of coronavirus.
Collection of information from or about children under the age of 18 requires the consent of their parent or guardian.
We do not transfer personal data outside the UK, the EU or to anywhere else.
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, the right to rectification on 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 our data protection manager Ranjeet Johal in the first instance to resolve your issue.
If you are still not satisfied, you can complain to the Information Commissioner’s Office Information Commissioner’s Office (https://ico.org.uk/)
Please contact our data protection manager Ranjeet Johal with any queries.
We keep our privacy notice under regular review, and we will make new versions available via this notice board or on our privacy notice page of our website. This privacy notice was last updated on 12 July 2021.