COVID – 19 Privacy Statement
Ramsay Health Care UK (“Ramsay”) has offered its full support to the National Health Service (“NHS”) to assist with its response to the COVID-19 outbreak, which will remain our focus for the foreseeable future. During these unprecedented times, Ramsay’s main priority is the health and safety of our patients, our people and our communities.
As a result of these unique circumstances, Ramsay may need to share personal data with the NHS and other regulatory and government bodies. Each of our hospitals is working in collaboration with their local NHS trusts to ensure we can provide the right help, exactly where and when it is needed and this may involve personal data being shared with us by the local Trust. This will be done in accordance with data protection legislation and any amendments to applicable legislation made by the Secretary of State. We will also consider any guidance provided by the Information Commissioner’s Office.
Ramsay’s role in responding to the COVID-19 pandemic may vary in relation to demand. At times the NHS and its healthcare professionals will provide you healthcare services at a Ramsay hospital; in this event the privacy notice of the relevant NHS Trust may also apply.
The purpose and lawful basis on which Ramsay will process your data is set out below:
Using your personal data and the legal bases for processing
Ramsay will rely on Article 6 (1)(b) and Article 9 (2)(h) for the processing of your data. In addition Ramsay will rely one or more of the following basis when sharing personal data as part of our support work with the NHS during the COVID-19 pandemic:
- Legal obligation: the processing is necessary for compliance with a legal obligation Article 6 (1)(c)*
- Vital interests: the processing is necessary to protect someone’s life. Article 6 (1)(d)
- Public interest: the processing is necessary to perform a task in the public interest. Article 6 (1)(e)
- Legitimate interests: the processing is necessary for an organisation’s legitimate interests or the legitimate interests of a third party Article 6 (1)(f)
When processing special category data for the purposes of:
- Employment, social security and social protection Article 9 (2)(b)
- Vital interests of the Data Subject Article 9 (2)(c)
- Substantial public interest Article 9 (2)(g)
- Provision of health or social care Article 9 (2)(h)
- Public interest in the area of public health such as protecting against serious cross border threats to health Article 9 (2)(i)
* This includes the Notice by Secretary of State under Regulation 3(4) of Health Service Control of Patient Information Regulations issued 1st April 2020 allowing healthcare providers to share personal data and any other such notice that may be issued to support efforts against COVID-19.
Sharing personal information
During the COVID-19 pandemic your personal data may also be shared for the following purposes:
- Understanding COVID-19 trends and risks to public health and controlling and preventing the spread of COVID-19
- Identifying and understanding information about patients or potential patients with or at risk of COVID-19 including patient exposure to COVID-19
- Management of patients with or at risk of COVID-19 including: locating, contacting, screening, flagging and monitoring such patients and collecting information about and providing services in relation to testing, diagnosis, self-isolation, fitness to work, treatment, medical and social interventions and recovery from COVID-19
- Understanding capacity and availability information about patient access to health services and adult social care services
- Monitoring and managing the response to COVID-19 by health and social care bodies and the Government including providing information ( including workforce details) to the public about COVID-19
- Delivering services to patients, clinicians, the health services and adult social care services workforce and the public about and in connection with COVID-19
- Research and planning in relation to COVID-19.
Coronavirus (COVID-19) Priority Testing for Critical Workers
The Department of Health and Social Care (DHSC) has commissioned the virus testing programme on behalf of the UK. Ramsay employees may be invited to undertake a coronavirus priority virus test where they have been identified as a critical worker and following government guidelines on self-isolation. Tests are completely voluntary and we do ask that you share your results with Occupational Health through your Head of Clinical Services, to facilitate return to work arrangements. Ramsay will arrange the appointment on behalf of the employee and further information on how personal data will be handled by the testing facility can be found at: https://www.gov.uk/government/publications/coronavirus-covid-19-testing-privacy-information.
How we communicate with you
During the COVID-19 outbreak, in order to continue to provide certain health care treatment, your Consultant or other health care professionals may need to contact you in different ways. Please ensure that we hold your up to date contact details.
It may also be appropriate to arrange a remote consultation with you, including telephone or video calls. Your information will be used in the same way as it would during a face to face appointment. Ramsay will not retain recordings of remote consultations.
Further guidance on remote consultations will be provided to you when your appointment is arranged.
Data Subject Rights
Please be aware that due to the current circumstances, if you submit a Subject Access Request (SAR) or other Data Subjects Rights request, you will undoubtedly experience delays in our response. That’s because we will be diverting resources to help with other challenges and ensuring the ongoing healthcare and treatment of our patients.
We assure you that all necessary steps will continue to be taken to maintain the security of your personal information and our focus will be to prioritise information flows, to ensure ongoing safe and effective care during these unprecedented times.
If you have any concerns or questions about our use of your personal data, you can contact our Data Protection Officer via email at firstname.lastname@example.org
Changes to this Privacy Statement
We will regularly review this privacy statement and its applicability throughout the COVID-19 outbreak. We reserve the right to update this privacy statement at any time, and we will provide you with a new privacy statement when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
This Privacy Statement was updated on 20 April 2020