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Privacy notice for Mandatory COVID-19 Vaccination for CQC Registered Care Homes, Privacy Notice for Staff and Contractors 

What is the purpose of this document?

Ramsay Health Care UK is committed to protecting the privacy and security of your personal information.

This privacy notice explains how personal information is collected as part of the mandatory COVID-19 vaccination programme for individuals that work or visit a CQC registered care home in accordance with Data Protection Legislation (UK GDPR). 

This privacy notice applies to all employees, workers, contractors, consultants and individuals providing services within a CQC registered care home.

Ramsay Health Care UK is a "controller". This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

Under the Health and Social Care Act 2008 (Regulated Activities) (Amendment) (Coronavirus) Regulations 2021, employers of all CQC registered care homes must ensure that all staff working within the care home, or professionals, such as healthcare workers, tradespeople, hairdressers, beauticians and CQC inspectors, visiting the care home, have been fully vaccinated against Covid-19.

Staff or individuals that have certain allergies to the vaccine ingredients or conditions which are medically recognised as reasons not to administer the vaccine, will need to follow the process outlined in the UK Government’s operational guidance to apply for an exemption. 

The mandatory vaccination requirement commences on 11 November 2021. After that date, any individual who is not fully vaccinated will not be able to enter a CQC registered care home in order to work or to carry out duties within their role. If you would like further information regarding this please contact your HR Coordinator

What personal information we collect?

In order for us to maintain a record of the vaccination status of all staff and professionals that work in, or visit one of our CQC registered care homes, we will collect the following personal information:

  • Name;
  • employee number;
  • job title;
  • vaccination status, this will include the dates of vaccinations, sources of evidence and date of booster if and when applicable
  • Where an exemption is provided, no detail of the nature of the exemption needs to be recorded, only that the manager has had sight of the evidence of redemption

Who we share your information with?

When required by law, we will share minimum amount of personal information with the following partners and agencies:

  • health service providers including NHS agencies;
  • care providers, e.g. day care, domicillary residents;
  • Government agenies e.g. Department of Health;
  • Regulatory bodies, e.g. CQC;

The lawful basis for the processing

We have a legal obligation (UK GDPR Article 6 (c), where the basis in law is met by the Health and Social Care Act 2008 (Regulated Activities) (Amendment) (Coronavirus) Regulations 2021.

When we collect data that is classed as special category data, under Article 9 of the UK GDPR we rely on the basis that we need the data for employment, or social protection (UK GDPR Article 9 (2) (b))

Protecting your information

Your information will be securely stored. We have put in place measures to protect the security of your personal information. Details of these measures are available in our internal policies found on the intranet. 

How long we keep your information for

The personal information will be held in line with our internal record management policies. 

If we need to use your information for any reporting, other than where we have a legal obligation to report identifiable data, your data will be fully anonymised and therefore out of scope of Data Protection. 

Will your personal data be transferred abroad?

No.

Your rights

Under UK GDPR you have a number of rights that are set out in our Privacy Notices.

Data Protection Officer

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO. You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO) with respect to data protection issues.

Further information can be found on the relevant privacy notice.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice 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. 

If you have any questions about this privacy notice, please contact DPO: dataprotection.officer@ramsayhealth.co.uk