This digital platform is designed to enable Circular1 Health and it’s users to log health information securely. We set out below information regarding how we will use your information collected for this purpose.
Please do not hesitate to contact our Data Protection Officer at [email protected] if you have any queries.
What processing activities do you undertake that include my personal information?
We will primarily process your personal information to ensure that you can be Tested for various medical and health issues, DNA/Epigenetic testing,
COVID-19 testing and notified of the status and result. We are legally obliged to report all COVID-19 test results to UK Health Security Agency (UKHSA).
We are also legally obliged to report confirmation of any notifiable organisms listed by UKHSA to UKHSA . We will also process your information to provide Flight Certificates for travel and Test to Fly services if required. We may process information relating to children that are registered under a parent/guardian account and this information will be processed according to GDPR regulations.
What categories of personal information are included in these processing activities?
To perform our Services, we need to collect and process the information requested on this digital platform. We also process information related to the medical Tests, including the Test results. This may include health information and special categories of personal information, including medical results and ethnicity (both are required for the Covid reporting to UKHSA). Special category information will always be processed according to UK GDPR regulations.
What is the reason for these processing activities?
We undertake this activity to perform our Services and to comply with our legal and reporting obligations under applicable law.
What are the legal grounds you rely on to carry these out?
This processing is also necessary for the purpose of the legitimate interests pursued by us in the performance of our Services and to help
us comply with our legal obligations.
What are the ‘legitimate interests’ referred to above?
It is in our legitimate interests to process your personal information in order to perform our Services, as we need to ensure that our Tests and notification service can be carried out in a way that can be properly attributed to you and so that we can report the Test results to you, our client and/or Public Health England.
As this processing may include special categories of personal information or information relating to health in addition to the above, what
are the additional legal grounds you rely on?
This processing is needed for carrying out preventative or occupational medicine testing Services, to meet public interests in the area of public health, to meet our reporting obligations under applicable law (such as our obligation to report Test results to UKHSA and for research and statistical purposes.
Also, as this is sensitive medical information, we use the following legal grounds under Article 9 GDPR and Schedule 1 DPA2018:
Where the data subject has given their explicit consent;
or it is necessary for the purposes of preventive or occupational medicine, medical diagnosis, or the provision of health care or treatment.
How did you collect this information?
Your personal information necessary to conduct our Services will initially be collected directly from you for this purpose.
Who do you share this personal information with?
Your personal information is shared with our Client. In addition, some of your personal information may be shared within our Group and with selected external service providers as needed to carry out the Tests and send out Results. (Further details of these can be found in