COVID-19 and Access to our Offices
The reasons why we use your personal data
This privacy notice describes how we may use your information during the Covid-19 outbreak.
To support NHS Test and Trace (which is part of the Department for Health and Social Care) in England, Assicurazioni Generali S.p.A. UK Branch (as Data Controller) 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?
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 Generali 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 are we allowed to use your personal data?
The use of your information is covered by the General Data Protection Regulations Article 6 (1) (f) – legal obligation.
It is in our legitimate interests and the interest of our staff, customers, and visitors that we collect personal data to help in the public health efforts to tackle Covid-19.
Who will 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
We will 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.
Your information will always be stored and used in compliance with the relevant data protection legislation.
By law, you have a number of rights as a data subject, such as the right to be informed, the right to access information held about you and the right to rectification of any inaccurate data that we hold about you.
You have the right to request that we erase personal data about you that we hold (although this is not an absolute right).
You have the right to request that we restrict the processing of personal data about you that we hold in certain circumstances.
You have the right to object to the processing of personal data about you on grounds relating to your particular situation (also again this right is not absolute).
If you are unhappy or wish to complain about how your information is used, you should contact a member of staff in the first instance to resolve your issue.
If you are still not satisfied, you can complain to the Information Commissioner’s Office. Their website address is www.ico.org.uk.
Date of issue – 17th March 2021
Review date – 12th April 2021