Data Privacy Notice: UniCoV App and COVID testing feasibility exercise

Data Privacy Notice: UniCoV-UCC App and COVID-19 testing Feasibility Exercise

Introduction to the Feasibility Exercise

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 sets out details of the information that we collect, how we process it and who we share it with. It also explains your rights under data protection law in relation to our processing of your data in relation to the feasibility exercise of the use of the UniCoV-UCC App in supporting: symptom checks, infectious disease risk checks, self-administered COVID-19 antigen testing and Saliva-sample collection.

This feasibility exercise is being undertaken to determine if the newly developed UniCoV-UCC app, the antigen testing kits, saliva collection tubes and any associated instructions and educational material, are feasible tools to support (1) self-administered antigen testing and saliva collection by students and staff of UCC, and (2) that assessment and advice is provided by the UCC Student Health Department having reviewed the data participants upload when using the app. The learnings from this exercise will confirm if the app is fit for purpose and suitable for further development to support the UniCoV research study. The UniCoV research study is a collaborative study between NUIG, UCC, UCD and TCD that will consider the role of various modalities of serial testing for COVID-19 in the university setting. It is due to commence in July  2021.

The feasibility exercise is not a research study and any of your personal data gathered by the UCC Student Health Department during this exercise will be used solely for the purposes listed in table below. These data will not be reported as part of the UniCoV study.

Who we are

Throughout this Notice, “we”, “us” and “our” refers to the Student Health Department, University College Cork. For more information about us, 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 part of the feasibility exercise. It will be used by us only in accordance with the purposes outlined in this notice.

Which personal data will we collect during this Feasibility Exercise?

The table below summarises the personal data that will be collected by us arising from your participation in this feasibility exercise 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.

Mobile Phone Number

To contact you if you require medical care

Location

To consider if other persons may need medical care if you are considered potentially infectious with COVID-19

Accommodation setting

To consider if other persons may need medical care if you are considered potentially infectious with COVID-19

Mode of transport to university

To consider if other persons may need medical care if you are considered potentially infectious with COVID-19

COVID-19 Vaccination Status

To assist in the risk assessment if you have been a contact of person with COVID-19

Symptoms of COVID-19

To assist in considering if you require referral for HSE COVID PCR test or other medical treatment

COVID-19 & other Infectious Disease Risk

To assist in considering if you require referral for HSE COVID PCR test or to restrict your movement or to have other medical treatment for non-COVID illnesses

Your interpretation of the result of your COVID 19 self-administered antigen test

To identify you as requiring consideration for HSE COVID –19 PCR test if you have interpreted your self-administered antigen test as either equivocal or positive

Photo-Image of your interpretation of the result of your COVID-19 self-administered antigen test

To assist in considering if a test you have interpreted as either equivocal or positive is accurate and so require referral by the Student Health Service for a HSE COVID-19 PCR test

 

The result of any COVID-19 test undertaken by the HSE arising from or associated with your participation in this feasibility exercise

To ensure you receive appropriate follow up advice and care.

The purpose and legal basis for collecting your data

Any personal data you provide to us via the UniCov-UCC App will be processed fairly and lawfully. It will be used for the purposes of:

  1. Facilitating you to:
    1. undertake a COVID-19 symptom check and an infectious risk self-check for COVID-19 and other infectious diseases prior to your on-site attendance in university.
    2. 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
    3. scan and submit a barcode that is unique to the saliva collection tubes you use as a participant in the feasibility exercise. This barcode contains no personally identifiable data.
    4. obtain a pass on the app advising you EITHER that it is deemed to be unsafe for you to attend campus and that you should remain at home (red pass) OR it is not deemed to be unsafe for you to attend on-site (green pass), according to your symptom check, infectious risk check, and the result of your antigen test
    5. receive e-mail advice from UCC Student Health Department as to what to do about your COVID-19 related concerns.
  2. Assisting the UCC Student Health Department, the Department of Public Health, HSE South, or Contact Tracing Services, in identifying your location(s) as part of any Covid-19 Contact Tracing Exercise.

The University requires the use of your data to  to undertake a feasibility and logistical testing exercise of the IT supports, data exchange, and business processes involved in the upcoming UniCov research project. It will also serve to reduce the risk to the individual user and to the university setting posed by COVID-19.

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 feasibility exercise.

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, and/or Contact Tracing Services

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 id amd 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 12 months to cover the timescale by when most of the population of Ireland will have been offered and completed vaccination against COVID-19. 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 COVID-19 testing feasibility exercise , 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.

 

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