COVID 19: Return to Work Safely Protocol
Data Protection Transparency Notice

Introduction

On 1^st May 2020, the Government published a ‘Roadmap for Reopening Society and Business’ to ease the COVID-19 restrictions and reopen Ireland’s economy and society in a phased manner. In conjunction with this roadmap, a ‘Return to Work Safely Protocol’ has been agreed between employers, unions and the Government and this is in now place for all businesses, including the CSO. The protocol describes the measures required to be put in place by employers and adhered to by workers to reduce the risk of the spread of COVID-19 in the workplace.

This transparency notice describes what employee information will be collected and what it will be used for. It explains why we process this information, the legal basis for processing the information, with whom the information is shared, how long the data will be retained and provides information on your Data Protection rights.

Purpose and Legal Basis

Civil and Public Service employers including the CSO are obliged to provide a safe workplace for their employees, this includes the processing of employee health information to ensure that the working environment is safe for all employees. The CSO has a legal obligation to protect the health and safety of their employees under the Safety, Health and Welfare Act 2005 (as amended). The Government ‘Return to Work Safely Protocol’ requires certain measures to put in place by the CSO and adhered to by staff so as to reduce the risk of the spread of COVID-19 in the workplace.

As part of this protocol and the requirement of CSO and staff to comply with the Safety, Health and Welfare Act 2005 (as amended) CSO staff members are required to complete the following COVID-19 forms:

• Return to Office Form, this form should be completed and returned to HR section 3 days before an employee returns to work in the office;

• CSO Daily Contact Log, this form should be completed each day or part of a day an employee attends the office

The data you provide for the CSO COVID-19 ‘Return to Work Safely Protocol’ will be processed by the CSO in accordance with Articles 6(1)(c), 9(2)(b), (h) and (i) of the General Data Protection Regulation and sections 46, 47, 52 and 53 of the Data Protection Act, 2018.

What information will be collected, who will it be shared with and how long will it be retained?

HR will collect the following information from individuals to help prevent the spread of COVID-19 in the workplace.

• Demographic data – your name, section details, work location
• Health Information – information relating to your health and COVID-19 as detailed in the Return to Work form
• Details of close contacts whilst attending the workplace

The personal data collected for the COVID-19 ‘Return to Work Safely Protocol’ will be shared with relevant HR staff, and other Government departments or agencies where deemed necessary for the protection of staff and public health during the COVID-19 emergency.

The Demographic and Health Data will be retained for as long as is necessary to protect the health of staff and the public during the current COVID-19 emergency and will be deleted within 6 months of the COVID-19 emergency ceasing. The personal data collected from the ‘Daily Contact Logs’ will be retained for 4 weeks and will then be deleted.

Are there transfers to third countries and if so, what safeguards are in place?

No information will be transferred abroad.

Profiling or automated decision making?

No data will be used for automated decision making or profiling.

Data Protection Rights

Under the General Data Protection Regulation, you have the following rights:

• The right to lodge a complaint with the Data Protection Commission. Contact Details: Office of the Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland.
• The right to request access to and rectification of or restriction of the processing of your personal data
• You do not have the right to erasure, portability or to object to the processing of your personal data because the data is processed under a legal obligation.

Further Information or Complaints

If you have any queries in relation to this data protection notice, or if you have any queries as to how your data is processed, please contact Catherine Desmond, HR (email Catherine.Desmond@cso.ie). 

Statistcs Office Data Protection Officer Contact Details:

DPO@cso.ie