Data Protection Notice – Covid-19 – Pre-Entry Screening
A prison is an enclosed environment in which the management of outbreaks of any infectious disease can put the health and welfare of staff and prisoners at risk, particularly given the use of shared facilities and the close proximity of people (staff and prisoners) in the prison. Therefore, it is necessary to take appropriate steps to mitigate the risk of an infectious disease such as Covid-19 from entering the prison population from outside. This is for the protection of the vital interests of all those present in the confines of the prison.
Who do we process data about?
All employees to include prison staff and administrators
All visitors to the prison, including deliveries and other service personnel.
All data which will be processed shall only be processed for the purposes of screening for risk of infection, in line with the WHO guidelines on Prevention and Control of Covid-19 in Prisons.
What do we do with your data?
You will be asked some simple screening questions to identify potential risk factors for Covid-19 infection. We will also take your temperature using a calibrated thermal scanner.
If you answer yes to certain questions, or if your temperature is over 38 degrees Celsius when measured, you will be denied entry to the prison and will be asked to seek medical advice. Our screening does not constitute a diagnosis of Covid-19 or any other illness and is an infection control measure only.
Legal Basis for processing your data,
For the purposes of these screening checks, the Irish Prison Service rely on Articles 6 & 9 of the GDPR which relate to protection of the vital interests of others, the assessment of the working capacity of an employee, and for reasons of public interest in the area of public health.
Processing is also carried out for the purposes of the Infectious Disease Regulations 1981 in order to prevent the spread of an infectious disease.
Prison Service staff and visitors are directed to Part 7 and Part 8 of the Prison Rules 2007 in relation to the duties of Prison Governors and Prison Officers with respect to health and safety in the prisons and the authority of Governors to refuse entry to prisons to persons who do not undergo required screening.
Where do we get your data from?
Information is obtained directly from you through a questionnaire and from a non-invasive temperature check. This will be conducted in a discrete manner in an area that will allow for the maximum possible confidentiality of your answers.
No records are kept of your screening answers or your temperature check once the screening has been completed. Staff performing screening may be interviewed as part of a contact tracing activity and may share information about you that they recall for the purposes of supporting that public health function.
What are your rights and who should you contact?
Individuals have rights over their personal data under EU law. These rights are not absolute and some qualifications and restrictions will apply. As no data about you is retained by the IPS once screening has been completed, rights of access, erasure, rectification, or restriction of processing will not apply in this case.
If you have a query in relation to the screening procedure you can the Data Protection Officer at firstname.lastname@example.org.
Contact Details for the Office of the Data Protection Commission (Ireland)
Web: www.dataprotection.ie Address: Data Protection Commissioner, 21 Fitzwilliam Square South, Dublin 2, D02 RD28. email@example.com
Click on the link for PDF version Covid 19 Screening Data Privacy Notice 11.05.20