NHS Test and Trace scheme - Privacy Notice


  • Date of issue - 29 October 2020
  • Amended - 8 April 2022
  • Review date - 30 June 2022


The reasons why we use your personal data

This privacy notice describes how we may use your information during the COVID-19 outbreak. It supplements our COVID-19 Privacy Notice.

To support NHS Test and Trace (which is part of the Department for Health and Social Care) in England, Surrey County Council has decided to 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 the Coronavirus.

What processing of personal data is undertaken by the specific team(s)/services?

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 (such as surveillance of an individual's movements or marketing activities).

What Information do we collect?

As a customer/visitor of Surrey County Council you will be asked to provide some basic information and contact details. The following information will be collected:

  • The names of all customers or visitors, or if it is a group of people, the name of one member of the group.
  • A contact phone number for each customer or visitor, or for the lead member of a group of people.
  • Date of visit and arrival and departure time (if available).

How we are allowed to use your personal data

The use of your information is covered by the General Data Protection Regulations Article 6 (1) (f) – legitimate interests. The legitimate interest in this case is the interest of Surrey County Council in co-operating with the NHS Test and Trace service in order to help maintain a safe operating environment and to help fight any local outbreak of coronavirus.

Who we share your personal data with

We will only share information with NHS Test and Trace if it is specifically requested by them. For example, if another customer at the venue reported symptoms and subsequently tested positive, NHS Test and Trace can request the log of customer details for a particular time period (e.g.: this may be all customers who visited on a particular day or time-band, or over a two-day period).

NHS Test and Trace will not disclose this information to any third party unless required to do so by law (e.g. as a result of receiving a court order).

Retention of data

NHS Test and Trace have asked us to 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.

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 contact details). 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, unless this is superseded by a stop notice in relation to the COVID-19 public inquiry.

Your information will always be stored and used in compliance with the relevant data protection legislation.

Other information

For further information on our privacy notices, please see information and privacy.