Contact tracing privacy notice

The Travel Chapter is committed to respecting your privacy and will protect your Personal Information.

Key Summary

This Privacy Notice explains what Personal Information we process, why we process it, how it is legal and your rights.

We collect and process your Personal Information:

  • On behalf of the Owners for the purpose of contact tracing.
  • As a legal requirement for guest accommodation provided on a commercial basis to collect customer, visitor and staff contact details for contact tracing purposes. 
  • As a Joint Controller with the Property Owner as we have a close relationship to process your data and provide to the Owner.

We will share your personal information only with our Property Owners and our processor, please see section 1.1 and 6.1.

 

1.    Introduction

This Privacy Notice has been constructed from all the nations guidance (England, Wales and Scotland) for Covid19 Contact Tracing, and uses the term 'appropriate/applicable authorities' to mean the nations Public Health Officers/Officials.

Property Owners have been mandated by law to collect and keep a limited record of staff, customers and visitors who come onto their premises for the purpose of contact tracing.  By maintaining records of staff, customers and visitors, and sharing these with the appropriate authorities where requested, they can help to identify people who may have been exposed to the coronavirus.

We are The Travel Chapter Group. We operate a number of websites and brands including Travel Chapter. All references to “we” “our” “us” or “company” within this privacy notice are deemed to refer to The Travel Chapter Limited (company no 2431506), our ultimate parent company Country Topco Limited (company no 11724257), its subsidiaries, affiliates and/or any of our brands.

Our registered office is Travel Chapter House, Gammaton Road, Bideford, Devon. EX39 4DF, United Kingdom.

ICO Reference number: Z4968059.

We are a Controller under Data Protection Law and take your privacy seriously. We ask that you read this Privacy Notice carefully because it contains important information about how we process your Personal Information and your rights.

If you would like this Policy in another format (for example, audio, large print, braille) please contact our Data Protection Team using the contact details provided in section 2.

1.1   JOINT CONTROLLERS 

When using The Travel Chapter Test & Trace Web Form we will provide the information about you to the Owner of the property you will be visiting, who will process your Personal Information as a Joint Controller as we have jointly determined the purpose and means of processing for the purposes of contact tracing. Below shows the type of processing as joint controllers: 

The Travel Chapter

  • Description: We are providing the service to the Property Owner to collect your Test and Trace identity data before arrival at the Owners Property, if you are unable to use one of the other ways to register with the NHS Test and Trace service.
  • Data Location: Inside EU (UK)
  • Type of personal information processed: Identity data.

Property Owner

  • Description: The Property Owner will process your data sent by us in line with UK Privacy Laws only for the purposes of contact tracing.
  • Data Location: Inside EU (UK)
  • Type of personal information processed: Identity data.

 

2.    Our Data Protection Team

We have appointed a Data Protection Team who is responsible for overseeing any questions you may have in relation to this Privacy Notice and how The Travel Chapter will process your data.  Contact details are below:

Controller: The Travel Chapter

Address: Travel Chapter House, Gammon Road, Bideford, North Devon, EX39 4DF

Email: [email protected]

Telephone Number: 01237 426758

 

 3. Changes to this Privacy Notice

This version of the Privacy Notice was last updated on 22nd April 2021 and historic versions can be obtained by contacting our Data Protection Team using the contact details provided above.

This Privacy Notice may be updated from time to time.  If the change impacts you or your Personal Information, we will inform you of changes made to this Privacy Notice.

 

4.  The Personal Information we collect about you

We collect personal information about you only for the purposes of contact tracing and will collect the data when:

  • A guest completes our Test and Trace Web Form with their personal information

 4.1    PERSONAL INFORMATION

We collect the following Personal Information from guests over the age of 16:

Type of Personal Information: Identity data

Personal Information includes:

  • First Name
  • Surname
  • Phone Number / Mobile Number
  • If Phone / Mobile number not available, then email address collected
  • If neither phone number nor email address is available, then full postal address to be collected

 

5.    How we use your personal data

We are required to tell you what we use your Personal Information for and the lawful basis on which we can process your Personal Information:

Contact Tracing Service

  • Type of Personal Information: Identity data
  • Lawful basis for processing: Legal obligations
  • Details: To help the Property Owners comply with their legal requirements for contact tracing.

Transfer of data to the Property Owner

  • Type of Personal Information: Identity data
  • Lawful basis for processing: Legitimate interest
  • Details: We transfer your personal information to enable the Property Owner to comply with their legal requirements for contact tracing.

The use of your information is covered by the General Data Protection Regulations (the GDPR) Article 6 (1) (c) – a legal obligation to which both us as the agent to the Property Owner and the Owner themselves are subject to. The legal obligation to which we’re subject, means that we’re mandated by law, by a set of new regulations from the government, to co-operate with the applicable contact tracing services, in order to help maintain a safe operating environment and to help fight any local outbreak of coronavirus.

 

6.    Who do we share your Personal Information with?

We will not share your information with any other third party, only with the following:

  • Section 1.1 our Joint Controller (Property Owner)
  • Section 6.1 our Supplier (Processor)

 6.1     OUR SUPPLIER 

As part of our process we will use the following Service Providers: 

  • Processor: Mandrill (Service eMail Provider)
  • Description: The Property Owner will be sent you personal details by email.
  • Data location: Inside EU (UK)
  • Privacy Policy: Privacy Policy

We require all processors to respect the security of your Personal Information and to treat it in accordance with the UK privacy law.

 

7.   How long will the Property Owner hold the information

The Property Owner has been asked to retain your data for 21 days from the date of your visit, to enable contact tracing to be carried out during that period. If the Property Owner is contacted by an applicable authority, that Owner will only share information if it is specifically requested.

 

8.    Data Security

We use technical and organisational measures to safeguard your Personal Information, for example, when using our website, and we use secure connections on our website to ensure that your Personal Information is encrypted.  In terms of the latter, this means that we convert your Personal Information into a computer code, which will make it harder for third parties to access your Personal Information on our website. If you want to know how we are keeping your data secure, please contact our Data Protection Team who can provide more details.

While we will use all reasonable efforts to safeguard your Personal Information, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any Personal Information that is transferred from you or to you via the internet.  

 

9.    Your Legal Rights

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 processing of personal data about you that we hold in certain circumstances.
  • You have the right to object to 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 contact us about how your information is used, please use the information in section 2 in the first instance to try and resolve your issue.  If you are still not satisfied, you can contact the Information Commissioner’s Office. Their website address is www.ico.org.uk.