Key Workers

AuthorityDepartment of Health and Social Care
Date received2020-10-08
OutcomeNot upheld
Outcome date2020-12-04
Case ID1506165

Summary

The requester asked for copies of entry certificates issued to key workers under coronavirus regulations, but the Information Commissioner's Office did not uphold the complaint regarding the Department's response.

Key Facts

  • The request was made to the Department of Health and Social Care on 2020-10-08.
  • The outcome was 'Not upheld' on 2020-12-04.
  • The response included a sample entry certificate template dated 15 July 2020.
  • Key workers were permitted 'modified self-isolation' allowing travel to designated work premises.
  • Certificates were issued by the Cabinet Office under the Emergency Powers (Coronavirus) (Entry Restrictions) (No 2) (Amendment) Regulations 2020.

Data Disclosed

  • 2020-10-08
  • 2020-12-04
  • 15 July 2020
  • Regulation 6
  • 14 consecutive days
  • 24 pages
  • 5 documents

Original Request

Please provide me with copies of, or links to copies of, all entry certificates issued by the Department in respect of "Key Workers" under these regulations - https://legislation.gov.im/cms/images/LEGISLATION/SUBORDINATE/2020/2020/0279/EmergencyPowersCoronavirusEntryRestrictionsNo.2Regulations2020_6.pdf

Data Tables (12)

Isle of Man local workplace specific
COVID-19 mitigation measures. This may include the mandatory use of PPE and social distancing
or collection of personal details for contact tracing purposes. For further information please liaise
with the Isle of Man Site Sponsor or Designated Person for the workplace
In the event you choose to self-isolate with other persons who are not subject to these
mandatory, legal requirements to self-isolate (as outlined in the above conditions); the following
public health guidance is recommended:
 If you are self-isolating in a household with others who are not required to self-isolate
you must avoid contact as far as possible. This means having your own room and remaining in
it as far as possible. You must not share a bedroom with anyone who is not self-isolating. Your
room should be well-ventilated with a window to the outside that can be opened. Keep the door
closed.
 Use a separate bathroom from the rest of the household, if available. If you have to
share a bathroom regular cleaning will be required. If a separate bathroom is not available,
consider drawing up a bathroom rota for washing or bathing. You should use the facilities last,
before thoroughly cleaning the bathroom. You should use separate towels from other household
members, both for drying yourself after bathing or showering and for hand hygiene purposes.
 You should avoid using shared spaces such as the kitchen whilst others are present. Take
your meals back to your room to eat. Use a dishwasher (if available) to clean and dry your used
crockery and cutlery. If this is not possible, wash them by hand using detergent and warm water
and dry them thoroughly, using a separate tea towel.
Isle of Man local workplace specific
COVID-19 mitigation measures. This may include the mandatory use of PPE and social distancing
or collection of personal details for contact tracing purposes. For further information please liaise
with the Isle of Man Site Sponsor or Designated Person for the workplace
In the event you choose to self-isolate with other persons who are not subject to these
mandatory, legal requirements to self-isolate (as outlined in the above conditions); the following
public health guidance is recommended:
 If you are self-isolating in a household with others who are not required to self-isolate
you must avoid contact as far as possible. This means having your own room and remaining in
it as far as possible. You must not share a bedroom with anyone who is not self-isolating. Your
room should be well-ventilated with a window to the outside that can be opened. Keep the door
closed.
 Use a separate bathroom from the rest of the household, if available. If you have to
share a bathroom regular cleaning will be required. If a separate bathroom is not available,
consider drawing up a bathroom rota for washing or bathing. You should use the facilities last,
before thoroughly cleaning the bathroom. You should use separate towels from other household
members, both for drying yourself after bathing or showering and for hand hygiene purposes.
 You should avoid using shared spaces such as the kitchen whilst others are present. Take
your meals back to your room to eat. Use a dishwasher (if available) to clean and dry your used
crockery and cutlery. If this is not possible, wash them by hand using detergent and warm water
and dry them thoroughly, using a separate tea towel.
Isle of Man local workplace specific
COVID-19 mitigation measures. This may include the mandatory use of PPE and social distancing
or collection of personal details for contact tracing purposes. For further information please liaise
with the Isle of Man Site Sponsor or Designated Person for the workplace
In the event you choose to self-isolate with other persons who are not subject to these
mandatory, legal requirements to self-isolate (as outlined in the above conditions); the following
public health guidance is recommended:
 If you are self-isolating in a household with others who are not required to self-isolate
you must avoid contact as far as possible. This means having your own room and remaining in
it as far as possible. You must not share a bedroom with anyone who is not self-isolating. Your
room should be well-ventilated with a window to the outside that can be opened. Keep the door
closed.
 Use a separate bathroom from the rest of the household, if available. If you have to
share a bathroom regular cleaning will be required. If a separate bathroom is not available,
consider drawing up a bathroom rota for washing or bathing. You should use the facilities last,
before thoroughly cleaning the bathroom. You should use separate towels from other household
members, both for drying yourself after bathing or showering and for hand hygiene purposes.
 You should avoid using shared spaces such as the kitchen whilst others are present. Take
your meals back to your room to eat. Use a dishwasher (if available) to clean and dry your used
crockery and cutlery. If this is not possible, wash them by hand using detergent and warm water
and dry them thoroughly, using a separate tea towel.
Isle of Man local workplace specific
COVID-19 mitigation measures. This may include the mandatory use of PPE and social distancing
or collection of personal details for contact tracing purposes. For further information please liaise
with the Isle of Man Site Sponsor or Designated Person for the workplace
In the event you choose to self-isolate with other persons who are not subject to these
mandatory, legal requirements to self-isolate (as outlined in the above conditions); the following
public health guidance is recommended:
 If you are self-isolating in a household with others who are not required to self-isolate
you must avoid contact as far as possible. This means having your own room and remaining in
it as far as possible. You must not share a bedroom with anyone who is not self-isolating. Your
room should be well-ventilated with a window to the outside that can be opened. Keep the door
closed.
 Use a separate bathroom from the rest of the household, if available. If you have to
share a bathroom regular cleaning will be required. If a separate bathroom is not available,
consider drawing up a bathroom rota for washing or bathing. You should use the facilities last,
before thoroughly cleaning the bathroom. You should use separate towels from other household
members, both for drying yourself after bathing or showering and for hand hygiene purposes.
 You should avoid using shared spaces such as the kitchen whilst others are present. Take
your meals back to your room to eat. Use a dishwasher (if available) to clean and dry your used
crockery and cutlery. If this is not possible, wash them by hand using detergent and warm water
and dry them thoroughly, using a separate tea towel.

Full Response Text

Page 2 of 5

Version: 15 July 2020

and

ADHERE TO MODIFIED SELF-ISOLATION
AS SPECIFIED IN THIS ENTRY CERTIFICATE

This document is valid for the individual or group of persons named above to enter the Island.

It can be presented, if requested to do so as evidence of a direction of express exclusion from the entry restriction requirements in accordance with Regulation 6 of the Emergency Powers (Coronavirus) (Entry Restrictions) (No 2) (Amendment) Regulations 2020. You are recommended to carry a copy of this Certificate for the entire duration of your visit to the Isle of Man.

These entry “conditions” are made under the Emergency Powers (Coronavirus) (Entry Restrictions)(No 2) (amendment) Regulations 2020 and issued by the Cabinet Office to ensure the necessary precautions and public health measures can be taken to mitigate the risk of transmission of COVID-19 and forms part of your Entry requirements as authorised by the Cabinet Office.

YOU must ensure you adhere to the following conditions, it is a criminal offence under these Regulations for failing to comply.

Entry Certificate Conditions

Your Entry status is granted with ‘modified self-isolation’ conditions at a ‘specified premises’. “Modified self-isolation” permits you to attend another place for a particular reason subject to specific conditions outlined in this Certificate. At all other times, you must remain in self-isolation. Condition 1. Modified Self-Isolation (a) Upon your arrival to the Isle of Man you must proceed directly to the ‘specified premises’ referred to as: where you must remain in self-isolation for the duration of your stay EXCEPT for permitted attendance at the designated premises listed in Condition 1(e) (b) The ‘specified premises’ where you are to remain in self-isolation can include, the following types of premises: (i) a hotel room or bed and breakfast room with en-suite – where you are NOT permitted to leave the room for the period of self-isolation (except under condition 1(e)) or have any visitors enter the room as outlined in the conditions below. You must consume all of your meals in your Hotel Room. Arrangements will be made to ensure that meals are delivered to your Hotel Room. You must take all reasonable steps to avoid contact with the persons delivering your food. (ii) self-catering property, self-contained flat or apartment for which you are the sole occupier (or may include persons in your travelling party) and have access to your own entrance, bathroom and cooking facilities. (c) You may exercise within a garden (or other grounds) that forms part of the ‘specified premises’ where you are self-isolating. If the property has access to a garden (or other grounds) that is shared with others outside the group you are self-isolating with, you may only use it for exercise when others outside the group you are self-isolating with are not present in it. (d) You are not permitted to attend or socialise at any other place or premises (eg shops, restaurants, bars) whether indoors or outdoors for any other purpose than that specified in Condition 1 (e)

(e)EXCEPT you may as a key worker (as specified in Regulation 6 of the Entry Regulations) attend for work purposes the ‘designated premises’ only : or you are authorised to leave for the following purposes (i) If you are advised by 111, you are permitted to leave the premises to attend the COVID-19 testing centre; or (ii) if you are required to receive emergency medical treatment; or (iii) you are directed by emergency services or (iv) by any authorised Officer of the Cabinet Office.
You must take into account published guidance in respect of face masks, visiting policies, social distancing in these instances. (f) You are required to familiarise yourself with you own work based risk assessment that has been completed for the work to be undertaken whilst on the Isle of Man under the Health and Safety at work etc. Act 1974. This risk assessment should also address specific person, premises and task mitigation measures identified to reduce the risk of exposure to and transmission of COVID whilst at work on the Isle of Man. Note 1: All modified self-isolation conditions are lifted after you have spent 14 consecutive days on the Island in modified self-isolation. If you depart the Island within the 14 day period, your return to the UK doesn’t currently require you to complete any further self-isolation as the Isle of Man forms part of the Common Travel Area. You should follow public health guidance for travelling safely both on and off the Isle of Man. If you return back to the Island within the same 14 day period, the period of modified self-isolation is restarted and your arrival date is always considered to be day 1 of the modified self- isolation period. You must ensure you have a valid Entry Certificate for the period of travel and your period of stay on the Isle of Man. Condition 2 On- Island Travel (g) This Certificate permits your return movement between your specified place of self-isolation and workplace on the Isle of Man. The wearing of a face covering whilst travelling to, within and from the Isle of Man is required at all times including any indoor or outdoor places. This includes during meetings and other related activities etc. (h) You are not permitted to travel to or from the specified or designated premises by bus. You are permitted to travel by pre-booked taxi, in accordance with Condition 2 (g). You must follow local Isle of Man Public Health guidance issued and published at www.gov.im
https://covid19.gov.im/ for specific up to date guidance on travel requirements for non-Isle of Man Residents visiting and travelling around the Isle of Man.
Condition 3: COVID-19 Symptoms
(i) If you or any other person in your specified premises with whom you are self-isolating with (i.e. a member in your travelling party) develops symptoms you must telephone 111 for further advice. This is a dedicated Isle of Man COVID-19 health advisory telephone service. (j) If you subsequently are tested for COVID-19 (testing is only permitted under the specific instruction of the Isle of Man 111 COVID-19 telephone service) and confirmed COVID-19 positive, you will be issued with a specific direction by the Department of Health and Social Care (DHSC). This will require you to remain in self-isolation for a period of 14 days from the onset of your symptoms on the Isle of Man under the Emergency Powers (Coronavirus) Potentially Infectious Persons Regulations (as amended) 2020.
Any such Direction will superseded these ‘Entry Certificate’ conditions in respect of your self-isolation requirements. In such circumstance you are NOT permitted to attend work as specified in Condition 1(e) Page 4 of 5

Version: 15 July 2020

Condition 4: Departmental Specific Conditions (if required; blank if no additional conditions required)

(k) Sponsor –

14 DAY ISOLATION

FAILURE TO COMPLY WITH CONDITIONS: OFFENCES

Emergency Powers (Coronavirus) (Entry Restrictions) (No 2) (Amendment) Regulations 2020 (referred to as the “Entry Restrictions Regulations”)

It is an offence under the Entry Regulation 13 without reasonable excuse, if you fail to comply with these conditions or knowingly provide false or misleading information in an Application or requirement to provide information under the Entry Regulations. In such circumstances you may be liable to arrest and prosecution pursuant to Regulation 13.
Maximum penalty (summary) is 3 months’ custody and a fine not exceeding level 5 on the standard scale (up to £10,000) Your Personal Data and how we will use it:
The Cabinet Office will retain your personal data as outlines within its privacy notice. For more information about how we collect and how we use your information, please visit our Privacy Notice which can be accessed via this link: Cabinet Office 111 and Contact Tracing Privacy Notice This information will be used to ensure you are issued with the correct Conditions to mitigate the risk of COVID-19 transmission. The Cabinet Office may share your personal details with an authorised officer who may contact you by telephone or in person at your specified or designated premises to ensure your adherence to Conditions specified in this Entry Certificate. The following information is provided as guidance and does not form part of the ‘Entry Certificate Conditions’:
PUBLIC HEALTH GUIDANCE: Key Worker Arrivals to the Isle of Man Please refer to our dedicate COVID-19 website for the latest up to date information and guidance to protect yourself and our community from the transmission of COVID-19. https://covid19.gov.im/  It is your responsibility to ensure you are familiar with any local Isle of Man local workplace specific COVID-19 mitigation measures. This may include the mandatory use of PPE and social distancing or collection of personal details for contact tracing purposes. For further information please liaise with the Isle of Man Site Sponsor or Designated Person for the workplace  Under the Health and Safety at Work etc. Act 1974 it is the responsibility of your employer and employee to ensure an adequate risk assessment has been conducted for the tasks being undertaken. Such a risk assessment should take into account the risk of exposure to COVID-19 and identify relevant mitigation required to undertake the task safely. It is the responsibility of both the employer and employee to ensure this is undertaken and adhered to.

 You are required to self-isolate at all times (except those times when you are permitted ONLY to attend your place of work). Places of self-isolation may include: a hotel room or other similar establishment to mitigate the transmission risk of COVID-19. It is recommended the place of self- isolation is as close to the permitted place of work to reduce travel time and so far as possible encourage walking (whilst wearing face coverings). Please refer to our online guidance on how to self-isolate safely https://covid19.gov.im/general-information/self-isolation/

 The purpose of self-isolation is to ensure you can remain isolated from other persons to prevent the potential transmission of COVID-19. Therefore during self-isolation no other person should enter your residence.
 It is recommended that wherever you are self-isolating (e.g. a hotel room, or alone or in an excluded manner from the rest of the household (who are not self-isolating) that social gatherings and other visitors are avoided at the specified premises for the period of your self- isolation. It is recommended that no other person should to visit the premises other than (i) a medical professional providing care to you or a member of your household; (ii) a member of the emergency services who requires entry for the purpose of their work. You should advise any such person you are in self-isolation to ensure necessary precautions can be taken by yourself and the visitor to mitigate the spread of COVID-19.

 In the event you choose to self-isolate with other persons who are not subject to these mandatory, legal requirements to self-isolate (as outlined in the above conditions); the following public health guidance is recommended:  If you are self-isolating in a household with others who are not required to self-isolate you must avoid contact as far as possible. This means having your own room and remaining in it as far as possible. You must not share a bedroom with anyone who is not self-isolating. Your room should be well-ventilated with a window to the outside that can be opened. Keep the door closed.  Use a separate bathroom from the rest of the household, if available. If you have to share a bathroom regular cleaning will be required. If a separate bathroom is not available, consider drawing up a bathroom rota for washing or bathing. You should use the facilities last, before thoroughly cleaning the bathroom. You should use separate towels from other household members, both for drying yourself after bathing or showering and for hand hygiene purposes.  You should avoid using shared spaces such as the kitchen whilst others are present. Take your meals back to your room to eat. Use a dishwasher (if available) to clean and dry your used crockery and cutlery. If this is not possible, wash them by hand using detergent and warm water and dry them thoroughly, using a separate tea towel.  If you are travelling by local taxi, this should be pre-booked to and from your place of work, it is recommended you sit in the rear of the car, diagonally from the driver, high touch points (car door, seatbelts etc) should be sanitised after use, face coverings are required for all non IOM residents having arrived on the Island within the last 14 days.  You should ensure you have adequate local support and access to the delivery of food or medicines to your specified place of self-isolation. This may include the use of room-service where you are isolating at a hotel. Social distancing and good hand hygiene is essential to ensure any food or other items can be safely transferred to you whilst in self-isolation e.g. leaving items outside the premises door, therefore avoiding direct no person to person contact.  Information on support and local services who may be able to assist you safely whilst in self- isolation may be accessed by the COVID-19 Community Support Information Line – (this local Isle of Man service is for non-medical calls and queries) by telephoning 01624 686262.  Whilst persons who have been living on the Isle of Man for longer than 14 consecutive days are not mandated to socially distance, it is recommended since you have recently arrived from a potentially COVID-19 infected area, you are advised to adopt 2m socially distance standard at all times. END


Page 2 of 6

Version: 15 July 2020

This document is valid for the individual or group of persons named above to enter the Island.

It can be presented, if requested to do so as evidence of a direction of express exclusion from the entry restriction requirements in accordance with Regulation 6 of the Emergency Powers (Coronavirus) (Entry Restrictions) (No 2) (Amendment) Regulations 2020. You are recommended to carry a copy of this Certificate for the entire duration of your visit to the Isle of Man.

These entry “conditions” are made under the Emergency Powers (Coronavirus) (Entry Restrictions)(No 2) (amendment) Regulations 2020 and issued by the Cabinet Office to ensure the necessary precautions and public health measures can be taken to mitigate the risk of transmission of COVID-19 and forms part of your Entry requirements as authorised by the Cabinet Office.

YOU must ensure you adhere to the following conditions, it is a criminal offence

[Response truncated — full text is 61,837 characters]