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Vaccination programme privacy notice

You are either an Isle of Man resident expressing an interest in receiving a COVID-19 vaccination and then booking that vaccination, an Isle of Man resident booking a vaccination for a vulnerable young person or an Isle of Man resident who is eligible for a booster vaccination. This statement is designed to help you understand how your personal data or the personal data of the young person is processed by the 111 team and why. 

Personal data is data which relates to you when you can be identified from that data or from that data when combined with other information which is in the possession of or is likely to come into the possession of the 111 team.  The definition of personal data includes any expression of opinion about you and any indication of the intentions of the 111 team or any other person in respect of you.

If you feel that for any reason you might not understand what information we might ask you for, why we need it and what we might do with it, please contact the 111 team and select Option Two.  The team will be happy to discuss this document with you in person.

What personal data is processed and how is it used?

Please note that you will only be able to book an appointment for yourself unless you are booking an appointment for a vulnerable young person.

Booking your appointment over the phone

When you phone the 111 team, you will be asked for your full name (your forenames and surname) as well as your date of birth.  This is to enable the team to create a unique record for you within the CRM system that is used to hold information about the fact that you wish to receive the vaccination and subsequently the vaccination appointments you have booked. 

You will be given the option to provide a landline phone number or a mobile number so as contact can be made with you when a vaccine becomes available.  This number will also be used if you need to be subsequently contacted about your appointment or the 111 team need to make contact with you if you did not attend an appointment. 

When you initially phone the 111 team to express an interest in receiving the vaccine, the time of your call will be recorded.  This will be used to prioritise contact with you when a vaccine becomes available as appointments will be offered on a ‘first come, first served’ basis to those who have expressed an interest.

When the 111 team make contact with you to book your appointments, you will normally be given the option to provide a residential address or an email address which will be used to provide you with confirmation of your appointments.  You will be required to provide your residential address if you cannot attend the vaccination site and a vaccination in your home needs to be arranged or you can attend the vaccination site but you would like transport to be arranged for you to get there.

Your appointment dates and the location of your appointment will be retained within the CRM as will the fact that you have received the two vaccinations required.  This collection of data, as well as the data about your vaccination priority group, will be treated as part of your health data for the time that it is retained within the CRM system and the strictest standards of confidentiality will be applied to it.

Booking your appointment online

When you complete the online registration form, you will be asked for your title, your full name and your date of birth.  This information will automatically create a unique record for you within the CRM system that is used to hold information about the fact that you wish to receive the vaccination and subsequently the vaccination appointments you have booked.

You will be asked for your phone number which will be used by 111 to contact you and discuss possible vaccination dates.

You will be given the option of having your vaccination appointments confirmed by email or by post.  If you choose ‘email’, you will be asked to provide your email address.  If you choose ‘post’, you will be asked to provide a correspondence address.  You will not be prevented from providing your email address and your correspondence address if you wish to.

You will be asked whether you have experienced anaphylaxis in the past and if this is the case, your form will not be processed any further.  No copy of your response to this questions which would constitute your health data, will be retained. 

When you submit your registration form, the time and date of the submission will be recorded.  This will be used to prioritise contact with you when a vaccine becomes available as appointments will be offered on a ‘first come, first served’ basis to those who have expressed an interest.

Your appointment dates and the location of your appointment will be retained within the CRM as will the fact that you have received the two vaccinations required.  This collection of data, as well as the data about your vaccination priority group, will be treated as part of your health data for the time that it is retained within the CRM system and the strictest standards of confidentiality will be applied to it.

Booking an appointment for a vulnerable young person

When you phone the 111 team to book a vaccination appointment for a vulnerable young person, the same information as is set out above under ‘booking your appointment over the phone’ will be requested.  Some of that information will be in respect of the young person (name and date of birth) and some of it will be in respect of the person making the call (contact information).

The 111 team will also ask for some additional information in respect of the young person to ensure that an appropriate standard of care can be provided at the vaccination site.  This includes information about any previous reaction to vaccines as well as any particular access, communication or other requirements in respect of the young person.

If you are pregnant

If you are pregnant and you wish to receive the vaccination after your baby is born, you will be asked for your baby’s due date.  This will be recorded and will be used to ensure that you are contacted after the birth of your baby to arrange vaccination dates for you.

If you are eligible for a booster vaccination

If you are eligible for a booster vaccination, the 111 team will use information provided to them by Manx Care to allocate a date, time and location for your booster vaccination.  This information will include your name, your date of birth, when you had your second vaccine, the manufacturer of your second vaccine and the location of your vaccination.  Once the date and time have been allocated, the appointment information will be sent back to Manx Care so as they can issue you with an appointment letter. 

What is my data used for if I want transport to be arranged to get to the vaccination site?

If you advise 111 that you want transport to be arranged to get to the vaccination site because you cannot get there yourself, your name and address will be provided to the Transport Services Team within the Department of Infrastructure (the DOI) so as arrangements can be made to pick you up.  The 111 team will use your contact information to confirm the dates of your vaccination to you when confirmation has been received from Transport Services that they can pick you up.  Your name, address and date of pick up will be provided to the driver who will use these on the day that they are due to take you to your appointment.  If you do not wish to travel on that day, this will be advised to the 111 team by Transport Services.

When you book online, you are given the option of contacting the Transport Services Team yourself.

Where is the data stored?

Data will be held within the CRM system which is owned by the Cabinet Office of the Isle of Man Government and which is hosted on servers located in the Isle of Man.  If you wish to have travel arranged for you to the vaccination site, limited data about you will be retained in a secure area of the DOIs’ systems to enable sharing of the relevant information between the 111 team and Transport Services.

Who can see the information?

Your personal data will be accessible to the 111 team and to the vaccinator who is administering the vaccine or the booster vaccination to you.  The vaccinator will only be able to see the information that is required to verify your appointment and to update your record on the CRM system.  If you cannot attend the vaccination site and you need to have a vaccination or a booster vaccination at home, the vaccinator will be able to see your contact information and your residential address in order that they can attend to provide you with the vaccine.  If you need transport to the vaccination site, some limited data will be made available to Transport Services and the driver on the day.

If the vaccination is for a vulnerable young person, the vaccination shift team leader will have access to the additional information obtained in respect of that young person in order to arrange an appropriate standard of care at the vaccination site.

Will your data be used for marketing purposes?

Your data will not be used for marketing purposes nor will your data be provided to any third party so that they can market their products or services to you.

How long is the data kept for?

Personal data will be deleted from the CRM system within 48 hours of your record being updated to reflect that you have received both vaccinations or your booster vaccination.  Some anonymised data will be retained to assist with statistical reporting.  If you use Transport Services, the limited data about you will be held by the DOI for six months to assist with contact tracing if required.

Your rights

If you wish to see the data processed about you by the 111 team, please contact the Cabinet Office Data Protection Officer on:

Data Protection Officer
Cabinet Office
Government Offices
Bucks Road
Douglas
IM1 3PN
Email: DPO-CabOff@gov.im
Phone: +44 1624 686779

You have additional rights under the Isle of Man’s data protection legislation such as the right to rectification of incomplete data, the right to object and the right of erasure of data. 

If you wish to exercise those rights, or if you wish to make a complaint about how your data has been processed, please contact the Cabinet Office Data Protection Officer the details above.

You also have the right to request the Information Commissioner undertake an assessment as to whether the processing of your personal data has been carried out in accordance with the provisions of the Data Protection Act 2018. You can contact the Information Commissioner on +44 1624 693260 or by emailing ask@inforights.im

5 October 2021