- COVIDCert NI – Easy Read Privacy Information
COVIDCert NI – Easy Read Privacy Information
PRIVACY NOTICE – THE Covid Certification Service (CCS), COVIDCERT NI APP AND YOUR DATA
1. Why do we need COVID certification?
COVID Certification has been introduced to enable you to prove your Covid status via a certificate.
This may be used when required, for example if you wish to travel to a country that requires you to produce a Covid Certificate to gain entry to that country. To enable you to do this to the standards set by the European Union (EU), the Department of Health and Public Health Agency, through the Digital Health and Care NI (DHCNI) team, have developed and delivered the COVID Certification Service (CCS) and associated mobile COVIDCERTNI App (App).
People can now apply for a digital or paper-based vaccination/recovery or exemption certificate to travel abroad, or to use to access other events/venues if required locally.
2. What does the COVID Certificate Service and App do?
The CCS solution provides people with an easy way to get their COVID certificate.
This takes the workload off GPs and healthcare organisations to manage requests for proof of immunisation, test, and exemption information. This means they have more time to care directly for patients and those in greatest need.
The CCS and app help people in four ways:
- For people who want to travel abroad to share their immunity status and/or testing to enter countries they are travelling to.
- As lockdown restrictions are removed, there is increased domestic movement in outdoors and in closed venues like pubs, bars, restaurants, clubs, stadiums, etc. To help stop the spread of COVID and help people visiting these venues to stay COVID free visitors may be asked to share their Covid Certificate before they can enter premises and some events.
- To prove they have recovered from COVID-19 and have a PCR test result to prove their status
- CCS can also be used by people who are medically exempt from vaccination and wish to obtain a certificate. Exemption guidance can be found on the NIDirect website
3. Who is responsible for my data?
The Department of Health (DoH) and Public Health Agency (PHA) are Joint Data Controllers for the personal information processed in the CCS and mobile App and are responsible for making sure your personal data is safely and securely managed.
There are also organisations, called Data Processors, who the Joint Data Controllers allow to use your data to process and produce the COVID certificate, COVID app, recovery, and exemption certificates.
These processors are not allowed to use, store, or share your data with anyone else. The data processors use your personal data for the following purposes only:
- Civica- process your data to check you are fully vaccinated or exempt from vaccination. They develop the CCS and App and generate the certificates.
- Kainos store the record of your vaccination and share this with Civica when you apply for a certificate.
- BigMotive – have developed the website and app design you use to prove your COVID status.
- Department of Finance (DoF) – DoF are responsible for NI Direct website and the identity checking processes (NIDA), which processes your personal data to check and verify your identity before you apply for a Covid Certificate.
- Ernst & Young (EY) – will provide a team to conduct manual matching where the CCS cannot do this automatically and to maintain the certificate generation volumes. EY will also capture your data in the COVIDCert call centre for citizens to apply for exemption and recovery based COVIDCerts. The data you provide in applying for your Covid Certificate may be used by EY to ensure the quality of your data in the Vaccine Management System, to ensure your vaccine data on the VMS is accurate and up to date. In carrying out data quality checks EY will process your data utilising the Azure Synapse Analytics platform. The Azure Synapse Analytics platform is a data storage platform hosted on the public health information platform and controlled by the Public Health Agency (PHA). Data stored within CCS may also be analysed by EY to identify covid certification fraud.
- HH Global are sent your vaccination or exemption data to print out your secure certificate when you request a paper certificate.
- The Business Services Organisation (BSO) will process testing data on behalf of the PHA, as they host the Central Test Registry (CTR), which stores the public testing (Polymerase Chain Reaction (PCR)) test results.
- Surecert uses the data you give to NIDirect to confirm you are who you say you are.
- Belfast Health and Social Care Trust (BHSCT) is used to host the CCS application on their IT system, which is based in Belfast.
3. Why are you processing my personal information?
The DOH and PHA would not be able to deliver a digital or paper certificate to prove you are either fully vaccinated, in recovery or exempt unless we first prove your identity.
Once we have identified you, we can then check your vaccine or PCR test record and match these with the information you provide as part of the identity checks you will complete on NIDA. Matching your identity to your vaccine/recovery records allows us to deliver a digital certificate/recovery or exemption on the app or a printed version for those people who are unable to use the mobile app.
Public Health Agency (PHA) will review your exemption application should you not agree with the outcome.
Strategic Planning and Performance Group (SPPG), within the Department of Health, will process your exemption application in relation to the administration of service payments to GPs.
Trusts and GPs (who are separate Data Controllers) will process your exemption application, reviewing it in relation to medical records, to facilitate your application. Their processing of your data sits outside the CCS except for the processing of the outcome of their review of your application, which will be notified to CCS for the purposes of confirming whether a medical exemption certificate should be generated for you by the CCS.
4. What information about me is being collected?
We collect your data in line with European standards and UK Data Protection Legislation. We only collect the minimum data we need to process your certificate.
The data we collect includes your personal details (or your children under 18 if you are applying on their behalf) and intended travel details if you are travelling abroad.
If you use the COVID Certification Service and app to get a certificate for travel for yourself or your dependents under the age of 18, you will be asked to provide only the information we need to arrange that certificate(s) for the desired date of travel. People aged 16 and over may apply for a certificate themselves if they satisfy the NIDirect identity check requirements. Under-16s can also download the CCS app to store their Covid Certification on their mobile phone. They will need to download the app to their mobile phone, then scan the QR code available from their parents Covid Cert app.
Personal details collected for all travel, domestic, recovery and exemption certificates include:
- Full Name
- Date of Birth
- Health and Care Number (HCN)
- Mobile Number (this optional on NIDA)
For Vaccine Certificates we may ask for:
- Vaccination Centre (Optional; in case of other data mismatch)
If you are travelling abroad, we also need to collect your:
- Date of Travel
- Country of Travel
If you are trying to get a recovery certificate we need to know:
- Your PCR test date and type
Remember, the CCS, app, recovery, and exemption processes will never:
- Share any personal or health/medical information provided by you to anyone other than your GP practice patient record system.
- Ask you to dial a premium rate number (for example, those starting 09 or 087) to speak to us.
- Ask you to make any form of payment or purchase a product of any kind.
- Ask for any details about your bank account.
- Ask for your social media identities or login details, or those of your contacts.
- Ask for any passwords or PINs or ask you to set up any passwords or PINs over the phone.
- Ask you to download any software to your PC or ask you to hand over control of your PC, smartphone, or tablet to anyone else.
- Ask you to access any website or smartphone application that does not belong to the Government, or HSC.
5. What lawful basis are you processing my personal information?
We process your personal information according to the UK General Data Protection Regulation and the Data Protection (UK GDPR) Act 2018.
Your data is processed for CCS as part of our public task under UK GDPR Article 6(1)(e)).
The PHA and Dept of Health have a statutory duty to protect the health of the people in NI. This follows their duties under the Health and Social Care (Reform) Act (Northern Ireland) 2009., which include promoting a system that protects the physical and mental health of people in NI and helping to prevent, diagnose, and treat illness such as COVID-19.
Because the CCS provides a range of digital and non-digital services to help people to prove their COVID status, which would be considered health related data, we are also required to meet the following UK GDPR and Data Protection Act conditions:
UK GDPR laws we must follow are:
- UK GDPR Article 9(2)(h) – the processing is necessary for medical diagnosis, the provision of health treatment and management of a health and social care system.
- UK GDPR Article 9(2)(i) – the processing is necessary for reasons of public interest in public health.
Data Protection laws we must follow are:
- Data Protection Act 2018 Schedule 1, Part 1 (2) – Health or Social Care Purposes
- Data Protection Act 2018 – Schedule 1, Part 1 (3) – reasons of public interest in public health
6. How will my data be processed?
Your data will be processed in line with legal requirements in section 5. We do this in a way to ensure the proper security of your personal data.
This includes protecting your data against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate means.
The CCS app asks your permission to use the camera functionality on your phone to capture a ‘selfie photo’. The photo is stored on your phone only. It does this to allow it to be displayed on your phone alongside the domestic 2D bar code (sometimes called a QR code), to show on the phone screen display. The app does not share your sensitive photo information with anyone, and it remains locked on the phone. Your photo is deleted when you uninstall the app.
If you have an older android device, when you chose to download a PDF version of your certificate you may be asked for access to your device’s file storage to download your COVID Certificate Service PDF documents. Files that you choose to download will then be stored on your device.
7. Do I need to give my consent?
While you will voluntarily choose to use the CCS service and/or the associated App, we do not process your data based on consent in relation to data protection legislation.
8. Where do you get my personal data from?
Much of the data we use will have been provided directly by you when you book your COVID-19 vaccination appointments, or when you have booked a test, (or by someone who booked these on your behalf), or when you call to begin the process for getting an exemption certificate.
If you are applying for a travel certificate for your children under 18, we use that data to generate their certificates.
Depending on the certification type you need the CCS receives data directly from the:
- Information you provided when booking your appointment and when attending for your vaccination, from the Vaccine Management System (VMS). The data we collect from the VMS about you includes:
- Number of doses you have had
- Your vaccination date(s)
- The vaccination manufacturer you received i.e., AstraZeneca
- The disease targeted – in this case COVID-19
- The vaccine product used
- Vaccine prophylaxis – meaning you were given an injection to help prevent COVID-19
- The vaccination batch number
- The place where you were vaccinated
- Data you enter onto the NIDA/Surecert portal for the purpose of identity verification when you access the portal on NI Direct to prove your identity
- For recovery we use personal data shared from the Central Test Registry (CTR) owned by PHA, to certify recovery within the CCS which includes your:
- PCR test date and test type
- Information you provided when applying for an exemption certificate and information provided by your GP/ Clinician regarding the outcome of the decision regarding your medical exemption application.
9. Do you share my personal data with anyone else?
We share your data with the organisations listed in section 3. They carry out functions on our behalf as ‘data processors’, to process, produce or print out your certificate/exemption.
Separately, you may choose to share your Covid Certification data as part of verification requirements for access to travel, or to gain entry to certain events, or hospitality premises.
Where a tour operator, organisation, or business needs to verify your Covid Status, they can use the separate COVIDCert NI Verifier App, which the Digital Health and Care NI team have developed and made available for the purposes of enabling your Covid Certificate to be scanned by an organisation who needs to verify your Covid Status. They will use the Verifier App to scan your 2D Barcode on your Covid Cert App, or paper copy certificate.
Organisations who use the Verifier App will be the data controllers for that processing and should provide you with separate privacy notices to explain how they use your data. The Department will not process any of your personal data on the COVIDCert NI Verifier App, however in the spirit of openness the Department has published a Privacy Notice, which explains how the App works, using minimal data and secure ways to ensure your data and privacy are protected and to ensure public trust in the use of the App.
10. Do you transfer my personal data to other countries?
Your data will be processed within the UK.
11. How long do you keep my personal data?
We will only retain your data for as long as necessary, in line with our Retention and Disposal Schedule (called Good Management, Good Records).
If there is a query, issue, or complaint about your application then we may need to retain the relevant emails and any document copies you supplied for up to 30 days to ensure we can resolve the issue. Those emails and your documents are deleted once the issue has been sorted out. These records will be retained for seven years (the current year plus six financial years).
- Your vaccine record on the CCS data store is retained for a day.
- We will only keep the record of you being issued a vaccine/exemption certificate in the CSS for a maximum of up to a 1 year after the date of travel/certificate issue.
- The record of your recovery certificate is kept in the CCS for 180 days from the date of your PCR test.
- Your data sent to the secure printers (HH Global) for provision of a paper certificate is retained for 30 days.
This may remain under review depending how long the pandemic lasts if the virus recovery period changes or if the NI government changes the law.
12. What rights do I have?
The GDPR sets out the 8 rights that you have in respect of your data.
a) Your right to be informed
You are provided with information about the collection and use of your personal data for the CCS, including what personal data is collected, the purposes for collecting, retention periods and potential sharing of data, as part of this privacy notice.
b) Your right of access
You can ask for copies of the information that we hold about you. You can contact the respective DPO as provided in Section 13 of this document.
c) Your right to rectification
You can ask to have inaccurate personal data corrected or completed if it is incomplete. You can contact the respective DPO as provided in Section 13 of this document.
d) Your right to be forgotten
GDPR introduced a right for individuals to have personal data erased/deleted (‘the right to be forgotten’), however the right is not absolute and only applies in certain circumstances, which do not include when processing is carried out under ‘public task’, which is the lawful basis under which the CCS processes data. However, the CCS will consider requests for erasure of data when received from individuals for their own data, or data related to their deceased relatives (where they have the authority to make such requests).
You should be aware that if you request your data to be deleted from CCS you will no longer be able to retrieve, access or update your Covid Status Certificates. If you wish to receive certificates in the future, you will need to reapply to the CCS and go through the full application process again. Once requested your detailed will be deleted within one month of the request.
e) Your right to restrict processing
You have the right to request the restriction or suppression of your personal data, however the right is not absolute.
f) Your right to data portability
You can ask the CCS to share your information with another organisation (although this may not always be possible). This does not apply to CCS.
g) Your right to object
You have the right to object to the processing of your personal data, including when the lawful basis for processing is a public task. However, this is not an absolute right, and processing can continue if there are legal grounds for the processing, which overrides your interests, rights, and freedoms as an individual.
h) Your rights relating to automated decision-making
You will not be subject to decisions made automatically by technology which may have a legal or significant impact on your rights. The CCS uses computer systems to process personal data for the purposes of matching of people’s records to the vaccination data and eligibility of COVID certificate based on the data on the number of doses received by the citizen.
However, app users can contact our helpline and progress their application manually if any issues are encountered. If you have any questions or concerns, please email us at email@example.com.
If you want more detailed information on these rights, this can be found on the ICO website, at: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights//
13. How do I complain if I am not happy?
COVID Certification Service and COVIDCert NI app
If you have a specific issue, or complaint, regarding the COVID Certification Service or the COVIDCert NI app, please contact firstname.lastname@example.org.
If you are unhappy with how your personal data is being processed by the COVID Certification Service please contact DPO@health-ni.gov.uk.
If you have a specific issue, or query regarding your vaccine data from the Vaccine Management System, or a complaint in relation to the processing of this data, please contact DPO.HSCB@hscni.net or DPO.PHA@hscni.net.
If you have a specific issue, or query regarding your test data from the Central Test Registry, or a complaint in relation to the processing of this data, please contact DPO.PHA@hscni.net.
If you have a specific issue, or query regarding your data and how it is processed for the purposes of the medical exemption certificate, or a complaint in relation to the processing of this data, please contact DPO.PHA@hscni.net.
If you are still not happy, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). Should you have any concerns about how your data has been handled or remain dissatisfied with any response regarding the processing of your personal data, you can raise these concerns with the ICO, as follows:
14. Changes to this Privacy Notice
This Easy Read Privacy Notice will be kept under regular review and any updated versions will be placed on our website.
15. Useful links
Users can also refer to the following links for further information:
Vaccine Management System Privacy Notice- https://covid-19.hscni.net/vaccine-service-privacy-notice/
NIDA Privacy Notice- https://www.nidirect.gov.uk/articles/nidirect-web-service-privacy-notice
PHA Testing Programme Privacy Notice – Test Data PN
All data processors are appointed under Data Processors Agreements in compliance with Article 28 of the UK GDPR, either via UK GDPR compliant contracts, or MoUs.
Under the terms of these arrangements DoH and PHA are the data controller responsible for assessing that all processors listed below, except DoF/ESS, are competent to process personal data in line with UK GDPR requirements. DoH is responsible for assessing that DoF/ESS are competent to process data in line with UK GDPR requirements under these arrangements. This assessment will consider the nature of the processing and the risks to the data subjects.
Under Article 28(1) DoH and PHA will ensure that only processors that can provide “sufficient guarantees” (in terms of its expert knowledge, resources, and reliability) to implement appropriate technical and organisational measures to ensure the processing complies with the UK GDPR and protects the rights of individuals. DoH will ensure the same regarding DoF/ESS.
Contracts or Memorandum of Understanding (MoUs) will be in place to govern relationships with the data processors, which set out the obligations of each party and the data controllers’ obligations and rights regarding the data that is being processed. All contracts adhere to established BSO Procurement and Logistics Services (PaLs) processes and legal input provided by BSO Department of Legal Services (DLS).
All data processing takes place within the UK area and as such is subject to legislation in the form of the UK – General Data Protection Regulation (GDPR) and Data Protection Act 2018.
The following provides a list of data processors involved in delivery of the system.
- Civica is a system integrator organisation who were chosen to develop the end-to-end CCS platform and are regarded as a processor contracted by the DoH/PHA. Civica will provide support on an ongoing basis to the CCS configuration for the duration of its operation, as part of their contract.
- Kainos will provide the citizen vaccination data that is part of VMS, to be used by Civica in CCS to match against the user entered information and process the COVID certificate request where applicable. Kainos are contracted by DoH/PHA.
- Big Motive is a software development company who were chosen to develop the CCS user interface and are responsible for the configuration of the CCS webforms and are regarded as a processor contracted by DoH/PHA. BigMotive will provide support for user experience (UX) design on an ongoing basis for the duration of the CCS operation, as part of their contract.
- Department of Finance, NIdirect/ NIDA – NIdirect is the official government website for Northern Ireland citizens which is run by DoF ESS. NICS Identity Assurance service (NIDA) is a service provided by DoF ESS via NI Direct for the purposes of identity verification. NIdirect aims to make it easier to access government information and services. It does this by working closely with Northern Ireland departments and other public bodies to collate key information based on users’ needs. DoH have a MoU in place with DoF/ ESS, which covers provision of these services.
- Surecert are an identity service that have been engaged to provide secure identity verification. Surecert supports the NIDA service delivered by the DoF. This service integrates with the NIDA service to provide real-time ID and Biometric identity checking service. Surecert are contracted by DoH/PHA.
- HH Global – HH Global are a UK government approved (framework CCS RM6170) secure printing organisation who produce NI’s secure printed certificates. Certificate data is sent to HH Global over an encrypted transfer protocol. These certificates incorporate several secure elements around the QR code, bar code and print layouts. These are done in accordance with the Four Nation COVID Certificate letter spec (release 2). DoH/PHA have a contract in place with HH Global for the provision of this service.
- Ernst & Young – will provide a team to conduct manual matching where the CCS cannot do this automatically and to maintain the certificate generation volumes. EY will also capture your data in the COVIDCert call centre for citizens to apply for exemption and recovery based COVIDCerts. The data you provide in applying for your Covid Certificate may be used by EY to ensure the quality of your data in the Vaccine Management System, to ensure your vaccine data on the VMS is accurate and up to date. In carrying out data quality checks EY will process your data utilising the Azure Synapse Analytics platform. The Azure Synapse Analytics platform is a data storage platform hosted on the public health information platform and controlled by the Public Health Agency (PHA). Data stored within CCS may also be analysed by EY to identify covid certification fraud.
- Business Services Organisation (BSO) – is a statutory organisation providing services as a data processor for PHA. BSO are responsible for monitoring and managing all Microsoft contracts as commissioned and monitored by PHA. They are responsible for all Civica environments user access and provision of new user hardware (PC and phones). BSO ITS are responsible for the supply and maintenance of user hardware. PHA have overarching SLAs with the BSO for services including ITS. Their services are managed via appropriate agreements with PHA
- Belfast Health and Social Care Trust (BHSCT). BHSCT is a statutory organisation providing VMS services as a processor for DoH and PHA. BHSCT host the CCS application on their infrastructure. Their services are managed via appropriate agreements with DoH and PHA.