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NHS Test and Trace scheme - Privacy Notice


The reasons why we use your personal data

This privacy notice describes how we may use your information during the Covid-19 outbreak. It supplements our existing privacy notice.

To fulfil our participation in the NHS Test and Trace England, Empire Cinemas is required to collect and keep a limited record of all customers who come to our premises for the purpose of contact tracing.

By maintaining records of customers and sharing these with NHS Test and Trace where requested, we can help to identify people who may have been exposed to the Coronavirus.

What processing of personal data will be undertaken?

Under government guidance, the information we collect will include additional information which we would not ordinarily collect from you when purchasing a ticket and which we therefore collect only for the purpose of contact tracing. Any data collected of this type will not be used for any other purposes (such as marketing).

What Information do we collect?

As a customer of Empire Cinemas you will be asked to provide some basic information and contact details. The following information will be collected:

(i) The name of all customers or visitors, or if it is a group of people, the name of one member of the group.

(ii) A contact phone number for each customer or visitor, or for the lead member of a group of people.

How we are allowed to use your personal data

The use of your information is covered by the General Data Protection Regulations Article 6 (1) (f) Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)

Who we share your personal data with

We will only share information with NHS Test and Trace if it is specifically requested by them. For example, if another customer at the venue reported symptoms and subsequently tested positive, NHS Test and Trace can request the log of customer details for a particular time period (e.g.: this may be all customers who visited and watched the same film as the infected customer).

NHS Test and Trace will not disclose this information to any third party unless required to do so by law).

Retention of data

NHS Test and Trace have asked us to retain this information for 21 days from the date of your visit, to enable contact tracing to be carried out by NHS Test and Trace during that period.

However, the government guidance may also cover information that we would usually collect and hold onto as part of our ordinary dealings with you (e.g.: Your Name and Email Address). Where this is the case, this information only will continue to be held after 21 days and we will use it under the usual conditions as outlined in our Privacy Notice.

Your information will always be stored and used in compliance with the relevant data protection legislation.