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Sharing of vulnerable person's information for the COVID-19 extremely vulnerable persons' service

The government is collecting information across England on people who are extremely vulnerable in relation to the COVID-19 virus who have been directed to stay at home and who need support with essential tasks such as getting food and medicine and accessing health and care services and support.

The government is sharing this information with the Portsmouth City Council for the delivery of the extremely vulnerable person's service (the service) as tasked by government in order to:

• facilitate the health and wellbeing of people who are extremely vulnerable
• ensure they can obtain essential supplies
• enable access to medical, health and mental health support

The council will be sharing necessary and relevant information with NHS Portsmouth Clinical Commissioning Group (the CCG), The HIVE and Solent NHS Trust who are all working together to ensure a coordinated response to Portsmouth residents and to provide the service to extremely vulnerable people.

• This may entail staff and/or volunteers from the CCG and staff and/or volunteers working in voluntary sector organisations contacting people directly, by telephone where possible, to offer them services and support, including help with shopping or food deliveries, regular outbound calls/welfare checks, prescription drop-off support and other forms of assistance as agreed with the person such as dog walking.
• In situations where a person is believed to be at risk of harm, their information may be shared with other relevant people or organisations to safeguard them from harm or to protect their vital interests.

The information shared with the CCG by the council includes people's name, address, contact details, medical conditions and details about whether they can get essential supplies delivered.

The legal basis for the CCG to process and share the information is provided by the General Data Protection Regulation (GDPR) Article 6 (1) (e)  Public Task. The CCG is relying on GDPR Article 9(2) (a) of the Data Protection Act 2018 to process and share special category (sensitive) personal information such as people's health information.

The CCG, as a data controller for the information shared by the council from government, undertakes to:

• access and process the information only for the purpose of delivering the service
• comply with data protection legislation at all times and not transfer information outside the UK or European Economic Area
• only process the information for as long as is necessary to deliver the service
• only share or allow access to the information where it is strictly necessary and with the person's consent
• has in place suitable technical, security and organisational measures to protect the information
• ensure that any third party with whom we share the information, including our systems suppliers, shall meet the requirements above and has in place suitable technical, security and organisational measures to protect the information.

Any queries or concerns about how the CCG processes and shares the information or requests for access to personal information should be directed to the Data Protection Officer, NHS Portsmouth Clinical Commissioning Group at: pccg.dpo@nhs.net or telephone 02392 899500. The full Fair Processing Notice for the CCG can be found here: https://www.portsmouthccg.nhs.uk/About-Us/looking-after-your-personal-information.htm