Privacy notices - Coronavirus (Covid-19)

This privacy notice explains how the Highland Council data processing may differ during the Coronavirus (COVID-19) Pandemic.  

The Council already holds data regarding tenants, applicants, homeless clients and members of the public. You may have provided this information for a specific reason and normally the Council would seek to inform you that the data provided would be used for a different purpose. Due to the rapidly emerging situation regarding the current pandemic this will not always be possible. If we already hold information regarding vulnerability as defined in the current guidance from the Government and Public Health Scotland, we may share this for emergency planning purposes or to protect your vital interests by sharing with services both inside and outside the council. 

Additionally, we may, in this current crisis, need to ask you or be provided with personal information including sensitive personal information, for example your age or if you have any underlying illnesses or are vulnerable, that you have not already supplied. This is so the council can assist and prioritise it's services. 

We always aim to collect the minimum data necessary to achieve the purpose required. 

We need the information to allow us to provide support to you while you are shielding. If you do not provide the necessary information we may not be able to provide this support to you.

The legal bases for processing by the council as a public authority Substantial Public Interest (Article 9(2)(g) of GDPR

The Council may process data and share data, both internally and externally, if it satisfies the Data Protection Act’s definition of ‘substantial public interest’ (Schedule 1, DPA18). Those relevant to the current emergency include using data for

• Statutory and government purpose

• Support for individuals with a particular disability or medical condition

• Safeguarding children and individuals at risk, and

• Safeguard the economic well-being of certain individuals

The Council is given powers by different Acts which can be used in the context of emergency data processing. For example, the Civil Contingencies Act 2004 allows councils to process data as part of complying with our duty to plan and prepare for, advise about, respond to and recover from emergencies.

Vital interest

The Council may process data, where processing is necessary to protect the vital interests of you or of another individual. For example, protecting someone or their property from imminent harm or damage. 

• Access to personal data
• Rectification of personal data
• Erasure of personal data
• Restrict processing of personal data
• Object to the processing of personal data

Find out more about your rights

The Council is part of the Highlands and Islands Local Resilience Partnership which is set up to deal with emergencies such as the Coronavirus pandemic.  The Council will share relevant and appropriate data with other members of the partnership.  The Council may also share information with voluntary organisations which are providing community assistance at this time.  Only the minimal amount of information required will be shared.

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Your personal information is not subject to automated decision making or profiling. 

The data controller is The Highland Council

Data Protection Officer
Highland Council Headquarters
Glenurquhart Road
Inverness
IV3 5NX
01463 702029   

dpo@highland.gov.uk

If you are unhappy with the way we have processed your personal information you can contact the Information Commissioner:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113
https://ico.org.uk/global/contact-us/