Track and Trace Privacy Policy

COVID 19 PRIVACY POLICYNORMAN PARK TRACK MANAGEMENT

Introduction: Scope of this Privacy Policy

This privacy policy applies to the customer, visitor and staff information that we will collect in order to minimise the risk of our customers, visitors and staff contracting or spreading COVID 19 (Coronavirus) and in support of the government’s COVID 19 contact tracing scheme.

There are two types of information that we will be collecting and (as explained below) they will be collected and handled differently:

(1)        COVID 19 Health Screening Questionnaire.   You will be required to complete a COVID 19 Health Screening Questionnaire electronically before you attend the track.  The questionnaire will require you to declare whether (within the last 14 days) you have had any COVID 19 symptoms, been in contact with anyone with suspected or confirmed COVID 19, been self-isolating or have a household member who has been self-isolating.

The Questionnaire will be completed by you once and (unless you request otherwise) it will be retained by Us until the COVID 19 public health crisis has come to an end; before or upon each subsequent visit to the track, you will simply be required to confirm that your answers to the Questionnaire have not changed.  (Note: If you request that We delete your Questionnaire, We will require you to complete a fresh Questionnaire before any subsequent visit.)

(2)        Contact Information Form.  You will also be required to complete a contact information form electronically upon arriving at the track.  This will involve the scanning of a QR code displayed at the track entrance (and at the pavilion) and the filling of a short electronic form:

(a)        providing your contact information;

(b)        confirming that you are in good health and that your health has not changed since you last completed the Health Screening Questionnaire;

(c)        confirming that you have read the Norman Park Athletics Track COVID 19 Track Usage Policy and agree to comply with current guidelines regarding social distancing.

You will have to complete a Contact Information Form every time you visit the track.

We know that you take the privacy of your information and how it is used and shared very seriously. We will only use your personal information in accordance with the current data protection laws and this privacy policy.  This privacy policy describes how We aim to repay the trust you have shown by sharing your personal data with Us.  This policy covers what We collect on our COVID 19 Health Screening Questionnaire and our Contact Information Form and why, what We do with the information, what We won’t do with the information, and what rights you have.  This privacy policy only applies to personal information We hold about individuals.  It does not apply to information We hold about companies and other organisations.  We may update this privacy policy from time to time by publishing the amended version on Our website.

Who We Are

In this policy, whenever you see the words (“We,” “Us,” or “Our”), it refers to Norman Park Track Management Limited.

 

(1)       COVID 19 Health Screening Questionnaire

Information We Collect

  1. Your name;
  2. Your telephone number;
  3. Your email address;
  4. Whether, within the last 14 days, you have:

(a)        experienced a new cough that you cannot attribute to a health condition other than COVID 19;

(b)        experienced a new shortness of breath that you cannot attribute to a health condition other than COVID 19;

(c)        experienced a new sore throat, loss of taste or smell that you cannot attribute to a health condition other than COVID 19;

(d)        had a temperature at or above 37.8c or the sense of having a fever;

(e)        had close contact with someone who is or was sick with suspected or confirmed COVID 19;

(f)        been self-isolating, or have a household member who has been self-isolating.

Why We Need to Collect this Information

For the health and safety of Our customers, visitors, staff and the general public, and in accordance with the guidance issued by England Athletics[1] regarding the creation of a “COVID Secure Environment”, we must gather health information pertaining to COVID 19 (for all attendees at the site) in a pre-activity health questionnaire.  The information is required in order to reduce the risk of spreading COVID 19.

How We Use the Information We Collect

We will only use this data for the following purposes:

  • To determine whether to allow you to enter the site;
  • To comply with any obligation upon us (relating to COVID 19) which arise pursuant to any laws, regulations or UK government requirements.

Choice / Opt-In and Opt-Out

Our processing of personal data in relation to the Questionnaire is not subject to opt-out, otherwise than where you have contrary rights under relevant data protection laws. We process this personal data pursuant to legitimate interests, Our legal obligations and to protect the vital interests of Our staff, customers and the general public.

Sharing Your Information

We may also share your personal information with the following persons but only in connection with the purposes set out above:

  • Our employees.
  • Hosting and infrastructure providers whom we use to host our servers and data, and to provide other services to Us.
  • Third party consultants, service providers, or contractors when providing support and other services to Us.
  • Advisers assisting Us in Our business operations.

Data Retention

We will keep the information that you provide in the Questionnaire until the COVID 19 public health crisis has ended, unless you request that We delete it following your visit.  (Such a request must be made by email to: normanpark@btconnect.com.)

If you request that we delete the information, we will retain it for no more than 3 weeks (21 days) following your visit to the track.  However, in this case, you will be required to complete a fresh Questionnaire before any subsequent visit to the track.

In any event, all data will be held and disposed of in a safe and secure manner.

 (2)      Contact Information Form

Information We Collect

  1. Your name;
  2. Your email address;
  3. Your telephone number;
  4. The fact that you visited the track;
  5. The date and time you visited the track.

Why We Need to Connect this Information

For the health and safety of Our customers, visitors, staff and the general public, and in accordance with the guidance issued by England Athletics[2] regarding the creation of a “COVID Secure Environment”, we must gather contact information for all attendees at the site.  The information is required in order to reduce the risk of spreading COVID 19.  It will be used to enable NHS England and its statutory partners to contact you as part of the “NHS Test and Trace” scheme,[3] in the event that you have been on site at or about the same time as someone who has tested positive for coronavirus.

How We Use the Information We Collect

We will only use this data for the following purposes:

  • To provide your details to public authorities, where requested, to enable those authorities to “contact trace” you for the purposes of managing COVID 19 infection monitoring and outbreaks;
  • To comply with any obligation upon us (relating to COVID 19) which arise pursuant to any laws, regulations or UK government requirements.

Choice / Opt-In and Opt-Out

Our processing of personal data in relation to the Contact Information Form is not subject to opt-out, otherwise than where you have contrary rights under relevant data protection laws. We process this personal data pursuant to legitimate interests, Our legal obligations and to protect the vital interests of Our staff, customers and the general public.

Sharing Your Information

We may disclose your personal data for the purposes set out in this privacy policy to government agencies and public bodies who legitimately request access to such data for the purposes of managing COVID-19 infection monitoring and outbreaks.

We may also share your personal information with the following persons but only in connection with the purposes set out above:

  • Our employees.
  • Hosting and infrastructure providers whom we use to host our servers and data, and to provide other services to Us.
  • Third party consultants, service providers, or contractors when providing support and other services to Us.
  • Advisers assisting Us in Our business operations.

Data Retention

We will retain the information that you provide in the Contact Information Form for no more than 3 weeks (21 days) following your visit to the track.  From that date, all personally identifiable data We store about you in connection with the Contact Information Form will be deleted.

All data will be held and disposed of in a safe and secure manner.

(3)       Your Rights

Under the data protection legislation, you have the right to request copies of your data, request rectification of your data, request erasure of your data, object to Us processing your data, utilize the right to prevent your data being used for direct marketing, request Us to restrict the processing of your data and, where Our systems allow, utilize the right to access a copy of the information We hold about you (a subject access request) and utilize the right to lodge a complaint with the relevant data protection authority.

We will require proof of your identity before we are able to provide you with any personal information that we have about you. The following information provides additional details about some of these rights and how to exercise them:

  • Right to Make a Subject Access Request (“SAR”)

You have the right to view and request copies of your personal data that We have about you. You may also request this information by contacting Us via one of the methods described below.

  • Right to Rectification

You can request that we rectify inaccuracies and missing information in personal data we have about you.

  • Right to Object to Processing

You may have the right to object to Us processing your personal data and request that We stop processing it. You may do this by contacting Us (see below for details).

  • Right to Complain

You have the right to raise a complaint about the processing of your personal data with the “supervisory authority”. In the UK, the supervising authority is Information Commissioner (www.ICO.org.uk).

  • Right to Request Erasure

You have the right to have your personal data erased where the data is no longer necessary for the purpose(s) for which it was originally collected/processed unless We have legitimate grounds or a legal right(s)/obligation(s) to store your personal data.

If you wish to exercise any of these rights, please contact Us (by email) at normanpark@btconnect.com or (by telephone) on 020 8462 5134.

 

[1]               https://d192th1lqal2xm.cloudfront.net/2020/07/EA-COVID-secure-environment-guidance-240720.pdf_0.pdf

[2]               https://d192th1lqal2xm.cloudfront.net/2020/07/EA-COVID-secure-environment-guidance-240720.pdf_0.pdf

[3]               For further information regarding the NHS Test and Trace scheme, see: https://www.gov.uk/guidance/nhs-test-and-trace-how-it-works