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Privacy Notice for Covid Test to travel to China (回国检测人员私人信息保护条例)

Privacy Notice for Covid Test to travel to China (回国检测人员私人信息保护条例)

PRIVACY NOTICE : Background Information for Covid Test to travel to China

Optipharm Pharmacy T/A Medicine Box (London) Ltd (whose company registered number is 11701368 with a registered office at 29 Bridge Road, Wembley, London HA9 9AB) (“Optipharm Pharmacy”) provides Covid tests to enable travel to People's Republic of China (“China”) (“China Covid Test”).

The government of China requires travellers who are to fly to China to apply for Health Declaration Certificate and in order to be able to undertake travel to China, you have chosen to book a China Covid Test with Optipharm Pharmacy. The China Covid Test will confirm if you currently have coronavirus or not and the results (positive, negative or unclear) will be forwarded on to the Embassy of the People's Republic of China in the United Kingdom of Great Britain and Northern Ireland at 31 Portland Place,London,W1B 1QD,London,W1B 1QD (“Chinese Embassy”) to enable you to travel/make travel arrangements to travel to China.

This notice is provided to you in advance of booking your China Covid Test, as required by the General data Protection Regulation 2016/679 as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 and as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (“UKGDPR”).\

What personal data we collect

The personal data that is collected and processed to administer the China Covid Test includes:

  • full name (which included first and last name)
  • date of birth
  • passport number and details
  • NHS number (if provided by you)
  • test result (health data), test date and report date
  • vaccination status (health data)
  • home and delivery address, including postcode
  • mobile phone number
  • email address
  • gender
  • passenger journey details (intended travel or journey details, route, date)
  • close contact details (the name and contact details of people you will travel with)

How will my information be processed by Optipharm Pharmacy?

Once you have taken the China Covid Test, your sample will be analysed in our laboratories and you will be informed of the result (positive, negative or unclear) by email.

Optipharm Pharmacy is the controller of your personal data obtained for the purpose of the China Covid Test and will use it for the following purposes:

  • confirming your appointment when you arrive for your China Covid Test
  • receiving and processing your test to obtain a result (health data)
  • returning your results to you
  • passing your personal data and test results (positive, negative or unclear), including health data to the Chinese Embassy
  • sharing your vaccination status with the Chinese Embassy

How your information will be shared by the Chinese Embassy

When we provide your personal data including health data to the Chinese Embassy, they will receive it as data controllers in their own right.

We will only share your personal data (including test results and health data) with the Chinese Embassy with your written consent which we will obtain from you in person, before you take the test.

In accordance with the UKGDPR, we hereby give you notice that China, and the Chinese Embassy are third countries from the perspective of the UKGDPR (which means they are not directly subject to the UKGDPR). Once your personal data including your China Covid Test results and other health data, is shared with the Chinese Embassy, it will be managed under the data protection laws of China, which may not offer the same protection to your personal data as the UKGDPR.

Your personal data will not be shared by us with any other third parties, although we use third party processors as software and storage providers, as set out in our general privacy policy (https://optipharmpharmacy.co.uk/policies/privacy-policy).  Third party processors do not process your personal data on their own behalf but are subject to our directions. Your personal data will remain under our control while processed by our third party processors in accordance with a data processing agreement which specifies their role in writing.

Lawful basis for processing your personal data

The UKGDPR requires that we explain to you what the legal basis is for our processing of your personal data (including health data). The lawful basis for our processing your personal data is the written contract you will sign in person (before you China Covid test) giving your instruction to us to administer the China Covid Test and your express written consent to our sharing your personal data (including health data) and test results (positive, negative or unclear) with the Chinese Embassy.

How long we keep information about you

We will retain your personal data on our own records for up to 7 years, in accordance with the laws applicable to us as covid test providers and for our own business administration purposes (legal and financial reporting obligations). We will dispose of your personal data sooner if it’s appropriate to do so.

We will store and process your personal data in the UK, however you have been notified above of the potential for your personal data to be transferred out of the UK to China following the China Covid Test result if you have given your consent to such a transfer in writing.

Personal data protection and storage

We handle your personal data in accordance with adequate and reasonable procedures and technologies in order to maintain and protect its security, availability, confidentiality and integrity, and prevent its unlawful or unauthorised processing, accidental loss or damage, from its collection until its destruction. More information on our storage and processing of personal data is set out in our privacy policy (https://optipharmpharmacy.co.uk/policies/privacy-policy).


Your rights

By law, you have several rights in relation to your personal data, these are set out in our privacy policy (https://optipharmpharmacy.co.uk/policies/privacy-policy).