So, @DHSCgovuk, when will you publish the #DPIAs for the "parts of" the #TestandTrace programme that your lawyers say are "in place"? And also all the #contracts & #SchemesOfWork?
#Transparency matters.
news.sky.com/story/coronavi…
Noting they aren't linked from even the most obvious place, i.e. @PHE_uk's 'Privacy Information' page: contact-tracing.phe.gov.uk/help/privacy-n…
The letter from @dhsc's lawyers to @OpenRightGroup is worth a read:
They claim 'alternate remedy' would be appropriate - a joke, given @ICOnews' evident unwillingness to act. (JRing ICO could have merits though.) And that to JR DHSC would be "academic"...
...on the basis that @DHSCgovuk(?) is working to 'finalise' the DPIA for #TestandTrace.
Well it's certainly not "academic" until the DPIA, contracts, schedules of work, etc. are all published.
#Transparency must mean what it says!
Timeline from @A__W______O, with links to Pre-action letter, Government’s response & AWO legal opinion:
And hey presto! @PHE_uk publishes (20 July) *another* generic #COVID19 'privacy information' page, this time under a GOV.UK banner - but still without links to any of the DPIAs:
gov.uk/government/pub…
So how many 'privacy notices' is that now? Let's see...
There's @PHE_uk's #TestandTrace privacy information page, masquerading under an NHS banner, though PHE is an Executive Agency of @DHSCgovuk, i.e. Government:
contact-tracing.phe.gov.uk/help/privacy-n…
Noting PHE claims to be data controller under Article 6(1)(e) of GDPR.
(First published 9 June)
Then there's @DHSCgovuk's own "Testing for coronavirus" privacy page - on which it claims to be the overarching data controller (acknowledging @NHSEngland, @NHSDigital & @PHE_uk may be too):
gov.uk/government/pub…
Note bullshit about "anonymous" data...
(Last updated 8 July)
And @NHSEngland's minimalist #COVID19 privacy notice: england.nhs.uk/contact-us/pri… points to info on the #DataStore: england.nhs.uk/contact-us/pri… but doesn't mention #TestandTrace - except maybe Pillar 1 lab tests, in passing?
(No date, but the Data Store DPIA wasn't published until June)
Then there's @NHSDigital's "transparency notice", which is pretty generic:
digital.nhs.uk/coronavirus/co… with no explicit mention of #TestandTrace - though it was last edited on 21 April, before T&T launched, and it does link to far more actual legal documentation than the others...
Finally, GOV.UK guidance on how #TestandTrace works: gov.uk/guidance/nhs-t… was last updated on 17 July, but *still* refers to trialling of the NHS coronavirus app on the IoW.
It links to a bunch of other information - inc. @PHE_uk's T&T site, i.e. full circle!
How regular members of the public are supposed to make sense of all this, I don't know!
Maybe doing an overarching DPIA, publishing and communicating it properly might've been a useful discipline?
#JustSaying
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