Data Protection Notice UniCoV Antigen Study
Data Protection Notice --UCC UniCoV Antigen App and UniCoV Antigen study
At University College Cork, we treat your privacy seriously. Any personal data which you provide to the University will be treated with the highest standards of security and confidentiality, in accordance with Irish and European Data Protection legislation. This notice provides information on how we process your personal data in relation to the UCC UniCoV Antigen App and the UniCoV Antigen Study. The notice describes the types of data we collect from you, how and why we collect it and who we share it with. It also explains your rights under data protection law in relation to our processing of your data regarding the use of the UCC UniCoV Antigen App and the UniCoV Antigen study. The UniCoV research study will consider the role of various modalities of testing for COVID-19 and other respiratory infections (e.g., Influenza) in the university setting. It will also look at the use of Point of Care Tests (POCT) in primary healthcare. It is due to commence in October 2022. Full information about the study is set out in the UniCoV Antigen Information Sheet.
Who we are
Throughout this Notice, “we”, “us” and “our” refers to University College Cork (UCC) - specifically the UniCoV UCC research study team and UCC Student Health Department. For more information about the UCC Student Health Department, please refer to our website: www.ucc.ie/en/studenthealth.
How we collect your personal data
We collect your personal data from you when you use the UniCoV-UCC App as a participant in the UniCoV research study. It will be used by us, only in accordance with the purposes outlined in this notice.
Which personal data will we collect via the UniCoV- UCC app during the UniCoV research study?
The Table below summarises the personal data that will be collected by us arising from your use of the UniCoV app and your participation in the UniCoV research Study, and the purpose(s) for which it will be used.
| Personal Data | Purpose |
|---|---|
| Name | To identify you if you require medical care |
| Email address | To contact you if unable to contact via phone. To be used as your unique identifier in the SharePoint database that is populated by the app. |
| Confirmation of consent to participate in UniCoV study | To ensure that you have completed the on-line electronic Consent to Participate in UniCoV study Form |
| Confirmation of understanding and agreement with this Data Privacy Notice | To ensure that you believe you understand and agree with this UniCoV App and UniCoV study Data Privacy Notice |
| Mobile Phone Number | To contact you if you require medical care |
| COVID-19 Vaccination Status1 | To assist in the risk assessment if you have been a contact of person with COVID-19. |
| Symptoms of COVID-191 | To assist in considering if you require referral for HSE COVID PCR test or other medical treatment |
| COVID-19 & other Infectious Disease Risk1 | To assist in considering if you require to have other medical treatment for non-COVID illnesses |
| Your interpretation of the result of your COVID 19 self-administered antigen test1 | To ensure you receive appropriate follow up advice and care. |
| Photo-Image of your COVID-19 self-administered antigen test1 | To assist in considering if a test you have interpreted as either equivocal or positive is accurate |
| Interpretation of the result of the clinician-adminsitered antigen test for COVID-19, Influenza A/B, Adenovirus, RSV | To ensure you receive appropriate follow up advice and care |
| Photo-Image of the clinician-administered antigen test for COVID-10, Influenza A/B, Adenovirus, RSV | To compare direct visual interpretation with image capture interpretation |
1in addition, these data will be used by the UniCoV research team to analyse and report on the various modalities of testing for COVID-19 in the university setting.
The purpose and legal basis for collecting your data
Any personal data you provide to us via the UCC UniCoV Antigen App and as participant in the UniCoV research study will be processed fairly and lawfully. It will be used for the purposes of:
- Facilitating you to:
- undertake a symptom check and an infectious risk self-check for COVID-19 and other infectious diseases prior to your on-site attendance in university;
- record your interpretation of the result of your self-administered antigen test twice weekly and to upload the image of the test strip to be reviewed by the UCC Student Health Department;
- scan and submit a barcode that is unique to the saliva collection tubes you may use. This barcode does not contain any personally identifiable data;
- receive advice on the app that you should remain at home according to any of; your symptom check, infectious risk check, or the result(s) of your antigen test(s).
- receive e-mail and telephone advice according to to any of; your symptom check, infectious risk check, or the result(s) of your antigen test(s).
- The UniCoV Antigen Research Study: The UniCoV UCC project team will use the data collected via the app to generate data reports using the Power BI reporting interface within Office 365 It will securely store pseudonymised data from the UniCoV Antigen research study and report on these data on an aggregate basis. Please note: You will not be identifiable from any reports generated. No data which would identify you will be shared. UCC is the Data Controller for all personal data collected.
Under GDPR (the EU General Data Protection Regulation), we are required to have a legal basis in order to process your personal data. We are relying on Article 6(1)(e) – where processing is necessary for the performance of a task in the public interests and Articles 9(2) (h) and (i) – where processing is necessary for reasons of public interest in the area of public health and for archiving purposes in the public interest, scientific or historical research purposes. We are also relying on your consent to take part in this study.
Who we share your data with
We will share your data with the following third parties where necessary for purposes of the processing outlined above:
- The Department of Public Health, HSE South.
- The data may also be shared with the UCC Corporate Secretary and your school/ department in the University, in the case of an infectious outbreak, on an anonymised no-name basis.
- The data may also be shared on a named non-anonymised basis with the UCC Corporate Secretary and your school/department where you have given express consent to disclose your identity, or if we have been directed to do so by Public Health Authorities. Where possible, you will be advised when this data has been shared in this manner.
Cross-border data transfers
The data is not subject to any cross-border transfer.
How long we will keep your data
In keeping with the data protection principles, we will only store your data for as long as is necessary. For the purposes described here, we will store your data for a period of five years. Your data will be stored in a secure server within University College Cork’s Microsoft Tenancy.
Your rights
You have various rights under data protection law, subject to certain exemptions, in connection with our processing of your personal data, including the right:
- to find out if we use your personal data, access your personal data, and receive copies of your personal data.
- to have inaccurate/incomplete information corrected and updated.
- in certain circumstances, to have your details deleted from systems that we use to process your personal data or have the use of your personal data restricted in certain ways.
- to object to certain processing of your data by UCC.
- to exercise your right to data portability where applicable (i.e., obtain a copy of your personal data in a commonly used electronic form.
- where we have relied upon consent as a lawful basis for processing, to withdraw your consent to the processing at any time.
- to not be subject to solely automated decision.
If you wish to avail of these rights, please contact the Information Compliance Manager, University College Cork, by email: gdpr@ucc.ie.
Questions or Complaints
If you have any queries in relation to the UniCoV-UCC App and UniCoV research study, please contact a member of the UCC Student Health Department on m.byrne@ucc.ie. If you have any complaints in connection with our processing of your personal data, you can contact UCC’s Information Compliance Manager (email: gdpr@ucc.ie).
You also have the right to lodge a complaint with the Data Protection Commission if you are unhappy with our processing of your personal data. Details of how to lodge a complaint can be found on the Data Protection Commission’s website (www.dataprotection.ie), or by telephoning 1890 252 231.
Revisions to this notice
Please note the University may revise this data protection notice from time to time. Any changes will be posted on the UniCoV-UCC app so you should periodically check the UniCoV-UCC app to review the most recent notice.