Thermal imaging - Council Buildings privacy notice

Read the privacy notice for Thermal imaging - Council Buildings

As the 'data controller' for the personal information - or data - we hold about you, South Ayrshire Council decides how your personal information is used/processed, and what it is used for.

This statement provides more details about this and provides information on how to get in touch with us if you need to know more.

What Personal Data will we collect from you?

Personal data is information relating to a living person who can be identified from that data. Identification can be based on the information alone, or in conjunction with any other information. The processing of personal data is governed by the General Data Protection Regulation 2016 (GDPR).

What Personal Data will we collect from you?

We will only collect the personal information we need to provide you with relevant information, services and support. The personal data we will collect includes:

Your photographic image
Your temperature (i.e. health data)

How will we use your information?

To ascertain if you have a temperature above 37.8°, which can indicate you have symptoms of the Coronavirus (COVID-19). We need to check your temperature to stop the spread of the virus and keep everyone accessing Council Buildings safe and healthy.

What is the legal basis for using/sharing your information?

We are collecting this personal data under the Council's requirement to carry out a task that is required for protection of the public (i.e. our public task, under Article 6(1)(e) of the GDPR) and in the vital interests of yourself and the public at large (i.e. to reduce the spread of the virus and maintain the health and public safety of individuals, under Article 6(1)(d) of the GDPR). Further information on the Council's statutory basis for collecting this data can also be found at: South Ayrshire Council COVID-19 Privacy Notice

As we are collecting health data from you, the data protection legislation also allows the processing of special categories data (e.g. health information):

As necessary, for "reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health" (Article 9 (2) (i) of the GDPR). The current pandemic is an example of this situation.
As necessary, in order to protect the vital interests of yourself or another person (Article 9(2)(c) of the GDPR);

Who will we share your information with?

If your temperature is below 37.8°	If your temperature is above 37.8°
Your information will not be shared	A member of reception staff, who may need to advise you cannot enter our Building Select Council Officers, to monitor to ensure our Buildings are safe to use Public Agencies, such as the Scottish Executive and Public Health Scotland for the purposes of Track & Trace

We want to reassure you that most of the processing of your data during COVID-19 is based on existing protocols we already had in place with partner organisations.

How long do we keep hold of your information?

We will not retain your image and temperature details if they are below 37.8°, but if your temperature is above this, your temperature status and image will be retained for 30 days.

What are your rights?

You can ask us to:

Correct your personal information if it is inaccurate;
Complete your personal information if it is incomplete;
Restrict the processing of your personal information in certain circumstances; and
Erase your personal information in certain circumstances.
You also have the right to object to the processing of your personal information.

What are the consequences of failing to provide personal information?

You will not be able to enter the Council Building you wish to visit. The Council must ensure do all we can to maintain public health and safety. If we cannot take your temperature, we cannot achieve this or demonstrate you are safe to enter one of our Buildings.

What about Automated Decision- Making?

The temperature scanner will automatically establish if you have a high temperature, however, this specific process is semi-automated and an actual person will always be involved before any decision is reached affecting your ability to enter our Buildings.

Do you require this statement in a different format?

Please contact us if you require this information in an alternative format.

How can you get in touch with us?

If you wish to obtain any records held by the Council relating to you, or if you have any general data protection queries, please contact the Council's Data Protection Service at:

Data Protection Officer
South Ayrshire Council
County Buildings
Wellington Square
Ayr
KA7 1DR
Email: DataProtection@south-ayrshire.gov.uk
Telephone: 01292 612 223

Are you dissatisfied with the way your Personal Information has been handled?

If you are unhappy with the way we have dealt with your personal information, you can complain to the Council's Data Protection Officer using the contact details noted above. If you remain dissatisfied after contacting us, you have the right to complain to the Information Commissioner (https://ico.org.uk/for-the-public/):

The Information Commissioner's Office - Scotland
Queen Elizabeth House
Sibbald Walk
Edinburgh
EH8 8FT

Email: Scotland@ico.org.uk
Telephone: 0303 123 1115