COVID Certification Service – Easy Read Privacy Information

To help this, the Department of Health, Health and Social Care Board 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 COVIDCert NI App (App).

People can now apply for a digital or paper-based vaccination, recovery or exemption certificate to travel abroad or use across Northern Ireland.

This takes the workload off GPs and healthcare organisations to manage requests for proof of immunisation and test data.

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:

1. For people who want to travel abroad. They will need to share their vaccination status or immunity status before entering countries that require it.
2. 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 need to share their vaccination status before they can enter these premises.
3. To prove they have recovered from COVID-19 and have a PCR test result to prove their status.
4. 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.

There are also 9 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 exemption record. 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 – We use NI Direct website’s captures your personal data in order to check and record your identity.
• Ernst & Young (EY) – Staff the CCS call centre and collect your data when you apply via the CCS website or if you apply online for an exemption/recovery certificate. EY may also use your CCS data to ensure quality of your data in the Vaccine Management System to ensure your data is accurate and up to date. EY may also use you data stored within CCS for analysis to identify covid certification fraud.
• HH Global are sent your vaccination or exemption data in order to print out your secure certificate.
• Surecert uses with the data you give to NIDirect to confirm you are who you say you are.
• Business Services Organisation (BSO) provide the CCS with proof of your PCR test result for recovery certificates.
• Belfast Health and Social Care Trust (BHSCT) is used to host the CCS application on their infrastructure which is based in Belfast.

Once we have identified you, we can then access your vaccine or PCR test record and match the two together. 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. 

For people who are exempt there is a different process. There are three government departments in Northern Ireland who have the authority to approve aspects of your COVID certification or exemption:

• Public Health Agency (PHA) will review your exemption application should you not agree with the outcome.
• Health and Social Care Board will process your exemption application in relation the administration of service payments to GPs.
• Trusts and your GPs are separate Data Controllers who will process you exemption application, reviewing it in relation to medical records, to facilitate your application.

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 if they satisfy the NIDirect identity/account requirements. Under-16s can download the CCS app and request their Covid Certification, this will only be stored on their mobile phone, this is done by scanning the QR code available from their parents account.

Personal details are collected to match your details against either your vaccination or PCR test records. The data we collect for you for all travel, domestic, recovery and exemption certificates include:

1. Full Name
2. Date of Birth
3. Postcode
4. Health and Care Number (HCN)
5. Mobile Number (this optional on NIDA)

For Vaccine Certificates we may ask for:

1. Vaccination Centre (Optional; in case of other data mismatch)

If you are travelling abroad, we also need to collect your:

1. Date of Travel
2. Country of Travel

If you are trying to get a recovery certificate we need to know:

1. Your PCR test date and type

Remember, the CCS, app, recovery and exemption processes will never:

1. Share any personal or health/medical information provided by you to anyone other than your GP practice patient record system.
2. Ask you to dial a premium rate number (for example, those starting 09 or 087) to speak to us.
3. Ask you to make any form of payment or purchase a product of any kind.
4. Ask for any details about your bank account.
5. Ask for your social media identities or login details, or those of your contacts.
6. Ask for any passwords or PINs, or ask you to set up any passwords or PINs over the phone.
7. 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.
8. Ask you to access any website or smartphone application that does not belong to the Government, or HSC.

Your data is processed for CCS as part of our public task to protect society under UK GDPR Article 6(1)(e)). 

The HSCB, PHA and Dept of Health have a statutory duty to protect people in NI. This follows the Health and Social Care (Reform) Act (Northern Ireland) 2009. Three sections of this act, 2(1), 2(3)g and 3(1)(b) require the NI health departments promote a system that protects the physical and mental health of people in NI. This law also requires NI health organisations to help prevent, diagnose, and treat illness such as COVID-19. 

More recently domestic use COVID certification regulations (The Health Protection (Coronavirus, Restrictions) Regulations (Northern Ireland) 2021) have been enacted in NI as a measure to slow down and prevent the spread of COVID infection.

Because the CCS provides a range of digital and non-digital services to help people to prove their COVID status to required standards we need to follow 3 UK GDPR and 3 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 the area of public health. 
• UK GDPR Article 9(2)(g) – the processing is necessary for reasons of substantial public interest.

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 the area of public health
• Data Protection Act 2018 – Schedule 1, Part 2 (6) para (1) – for reasons of substantial public interest.

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 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 barcode (sometimes called a QR code), to show on the certificate 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.

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 identityFor recovery we use personal data shared from the BSO Central Test Registry (CTR) to certify recovery within the CCS which just includes your :
• PCR test date and test type
• Information you provided when starting the exemption certificate process and information provided by your GP/ Clinician regarding the outcome of the decision regarding your medical exemption application.

They carry out functions on our behalf as ‘data processors’, in order 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 and transparency the Department has published a Privacy Notice, which explains how the App works, using data minimisation techniques to enhance data protection and privacy and ensure public trust in the use of the App.

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. 

• 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 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.

These are your rights when using the CCS and app:

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.

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.

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.

Your right to erasure: GDPR introduced a right for you to have personal data erased (‘the right to be forgotten’), however the right is not absolute and only applies in certain circumstances.

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.  While you can request that CCS stops processing your data, data will be held as described in number ‘d’ above.

Your right to data portability: You can ask the CCS to share your information with another organisation (although this may not always be possible).

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.

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 covidcertni@hscni.net

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/