Use of your data for COVID-19 Testing

Testing in Scotland

This Privacy Notice is being updated regularly as the different areas of the testing programme evolve. 

The UK government has established a new network of COVID-19 testing facilities. The UK-Wide Programme  runs alongside the existing NHSScotland programme of testing for clinical purposes and testing of key workers in health and social care.

The Department of Health and Social Care (DHSC, England) has been commissioned to run the UK-Wide elements of the testing programme on behalf of the NHSScotland, as well as Wales and Northern Ireland.

Within the next few days, weeks and months,  you may be invited to undertake a Covid-19  test

Depending on the test undertaken, it will confirm whether you currently have Covid-19 (antigen test) or if you had it (antibody test). The result of the test will enable you or the key worker(s) in your household to know whether to continue to self-isolate or whether it is safe to return to work.

If you do decide to take a test, we will need to collect some information about you in order to be able to conduct the test and communicate the result.

At the moment, we are still designing how some of these tests are going to be carried out and conducting the corresponding privacy assessments. We will continue updating this section as we have further details.

Scotland’s testing programme is very complex and includes local and UK-wide testing.

Testing via a UK Testing Centre

UK Testing Centres are managed by the Department of Health and Social Care (DHSC, England) on behalf of the UK.  In order to provide this testing service, they need to use some of your personal information.  The DHSC Privacy Notice provides an overview of the testing environment and what happens with your data within the DHSC programme, and how you will receive notifications of the result for tests booked via UK Testing Centres.

Testing via schools and other partner organisations.

The Department of Health and Social Care (DHSC, England) on behalf of Scottish Ministers, is also entering into agreements with other organisations, such as Scottish Local Authorities, in order to vaccinate their  staff and, for example, school students. In this scenarios, these organisations are also data controllers, for example:  Scottish Councils are responsible for the local management of the COVID-19 Lateral Flow Testing in their schools and Early Learning and Childcare settings; this includes the collection of data via forms and  logs for recording testing and vaccine stock information. Details about how your data is processed by these organisation is available in their own privacy notices, typically available from their websites.

Testing via your NHS Scotland Health Board

If you are taking a COVID test via NHS Scotland routes (e.g. your health board) instead of the UK Testing Centres, the NHS Scotland will  process the data in the same way they would do for any other tests regularly conducted through the NHS Scotland. You can find more information about how the NHS Scotland handles your data here

For COVID purposes, the NHS Scotland is also using the National Notification System. It has been built securely by NSS, StormID and the Digital Health and Care Institute. We use this system to send you a notification of your test result.

Your privacy rights

The testing programme does not take away or reduce your privacy and data protection rights. You can find more about your rights here.

We have completed Rapid Privacy Assessments of the testing data flows and have put in place the required agreements with those organisations that are helping in delivering the UK testing policy. 

Lead organisation(s)

Scotland’s testing programme is very complex and includes local and UK-wide organisations.

  • From the NHSScotland
    • Scottish Government as Chief Executive of the NHSScotland
    • Public Health Scotland, since COVID-19 is a public health matter.
    • NHS National Services Scotland in the provision of common services to other organisations across the NHSScotland.
    • Local Authorities (e.g. LFD at Home Testing for their staff and within some Education settings)  
  • From the UK Government, the Department of Health and Social Care (DHSC, England) is coordinating UK-Wide level testing on behalf of the NHS Scotland.

At different stages of the process these organisations are Data Controllers.

Other organisations will also carry out parts of the virus Testing programme on behalf of DHSC or the NHSScotland but can only act on instructions provided to them by DHSC. These organisations are known as data processors. An example of such an organisation is Amazon, who will support the actions involved with delivering test kits.

What data is used and how is used ?

If you do decide to take a test, we will need to collect some information about you in order to be able to conduct the test and communicate the result. 

We will collect your personal data such as:

  • your name,
  • address,
  • postcode,
  • telephone number,
  • CHI number etc.

In some cases, special categories of your personal data including your health information.

Test results will be shared with the relevant test subject.

Test result data, including the test result data of key workers, is provided by a variety of sources, including from UK run testing centres, NHSScotland laboratories and some commercial laboratories to allow maximum capacity on testing to be achieved. All of these results are filtered via NHS National Services Scotland to be aggregated into a single source of test data.

For testing being undertaken in Scotland instead of using the UK-wide route, health boards and laboratories process your data in the usual way as they would do for any other tests regularly conducted. You can find more information about how the NHS Scotland handles your data here.

From this aggregation of data, the key worker or test subject is notified of their test result using technology built by trusted partners with appropriate legal protections in place).

The test data will also be used, in anonymous datasets to help predict future waves of the pandemics or to identify hot spots.

The COVID-Testing Portal

NHS National Services Scotland (NHS NSS) administers the COVID Testing Portal. This online tool offers individuals a secure method to record their COVID-19 test results, including those who need to regularly report workplace related testing, such as hauliers, care home/social care and prison employees. This Portal allows you to submit your test results in relation to:

A. Lateral Flow Devices testing
B. Polymerase Chain Reaction (PCR) testing

You can access further privacy information about the COVID Testing Portal here.  


Click here if you want to know more about  booking of tests.


Return to the COVID-19 Privacy Statement main page.