Privacy Statement: Carolina Together Testing Program

The University of North Carolina Chapel Hill (“UNC-Chapel Hill” or the “University”) has implemented the Carolina Together Testing Program (“Program”) to protect students, faculty, and staff returning to campus. Under the Program, individuals returning to campus who are participating in in-person employment, clinical, educational or other activities on the UNC-Chapel Hill campus are required to comply with measures that may include daily health checks, training, regular COVID-19 symptomatic and asymptomatic testing, contact tracing, quarantine, and isolation. The groups of individuals required to participate in regular testing and frequency of those testing requirements is available on the Carolina Together Testing Program webpage. Records related to completion of these measures will be collected and maintained to manage the Program and meet state requirements. We respect your privacy and are committed to providing a transparent notice of our privacy practices describing the steps the University will take to protect the privacy of Program information while ensuring the health and safety of the UNC-Chapel Hill community.

Personal Data Collected Through the Program. Personal information is collected in the course of completing your requirements to return to the UNC-Chapel Hill campus including:

  • Daily Symptom Monitoring
    The daily University Employee Occupational Health Clinic (UEOHC) COVID Wellness Check tool for faculty and staff collects employee UNC ONYEN, contact information, and response as to whether or not you are experiencing any COVID-19 symptoms. The survey does not collect individual symptoms, only a response as to whether you have had any of a list of symptoms. This information is collected to monitor the number of people expected on campus and the overall incidence of COVID-19 symptoms at the University.
  • Asymptomatic Evaluation Testing
    Status of scheduling and whether a test has been completed is collected for individuals who are required to complete asymptomatic testing, including prior-to-arrival and evaluation testing. Scheduling data includes your UNC ONYEN, your contact information maintained in ConnectCarolina and whether or not you have scheduled and completed a required test. This information is collected to oversee compliance with required screening testing.

Test results from asymptomatic evaluation testing, including students with regular evaluation testing requirements and anyone who signs up for asymptomatic screening through HallPass, the mobile-friendly, web-based application, are stored and managed through the UNC lab information system. Test results maintained as part of the Carolina Together Testing Program will be linked to your PID and your contact information from ConnectCarolina, including your name, phone number, local address and email address. This information is collected to monitor the prevalence of COVID-19 and to follow up on positive test results, including contact tracing and isolation.

  • Symptomatic and Close Contact Testing
    Students: All students participating in prior-to-arrival testing are required to upload test results to ConnectCarolina. Positive test results obtained as part of your participation in the Carolina Together Testing Program will be managed in the same way as asymptomatic tests through the UNC lab information system. Students who have tested positive outside of the Carolina Together Testing Program are required to contact Campus Health at (919) 966-2281 to allow for contact tracing and to ensure isolation of positive cases.

Faculty and Staff: Faculty and staff members who have tested positive outside of the Carolina Together Testing Program are required to contact the University Employee Occupational Health Clinic (UEOHC) or call (919) 966-9119 to provide a copy of the positive test results to allow for contact tracing and to ensure isolation of positive cases. Test results of faculty and staff conducted outside of the Carolina Together Testing Program will be collected only with your explicit authorization.

  • Contact Tracing
    Contact tracing involves interviewing positive cases to identify individuals who have had significant exposure as defined by the US Centers for Disease Control (CDC) and local Health Department.  In accordance with the University’s COVID-19 Community Standards on contact tracing, if contacts meet the CDC and local Health Department criteria, their names and phone numbers will be collected. A different contact tracer will reach out to the contacts to notify them of the exposure. Contact tracers will not share the name of the individual with a positive test but rather will provide guidance on the need to quarantine and monitor for symptoms.
  • Location Data
    Access to buildings through card swipes may be reviewed in association with an individual’s authorization to be on campus or isolation status. Card swipe data includes building access points. IP address login information may be reviewed to determine high-density congregate spaces or to monitor counts of individuals in a given location.

Use and Disclosure of Your Personal Information
Data generated about students, faculty and staff through daily symptom monitoring, training, testing, and contact tracing are stored in databases and combined with information from ConnectCarolina, including phone numbers and/or email addresses, local addresses, and supervisors. Personally identifiable information collected for the Program will be used only for activities needed to promote campus safety or as required by law. UNC-Chapel Hill will use the information collected for the following purposes:

  • To monitor campus safety through aggregate Dashboard reports on compliance, positive test rates and other measures of public health.
  • To monitor compliance with the University’s COVID-19 Community Standards. Reports of individuals who are not in compliance with requirements will be shared as necessary to achieve compliance and may be sent to Institutional Integrity and Risk Management, Student Affairs and other University administrative offices as appropriate. On-going non-compliance by students or student organizations may be reported to the Office of Student Conduct for evaluation and disciplinary action in accordance with the University’s COVID-19 Administrative Process.
  • To meet North Carolina state requirements that UNC-Chapel Hill maintain documentation of faculty, staff, and student compliance with daily health checks. If authorized or required by law, compliance data may be provided to state and local authorities.
  • To alert Student Affairs and University administrative offices of positive student tests so that they can help students move to isolation housing, manage badge access, assist with academic accommodations, and ensure compliance with isolation requirements.
  • To monitor students, faculty, and staff identified as needing to quarantine to ensure campus safety. Reports of individuals subject to quarantine will be provided to Institutional Integrity and Risk Management and to Student Affairs who may share this information with other University administrative offices where appropriate.
  • To initiate disinfection of UNC-Chapel Hill facilities following a positive test result. Environmental Health and Safety will be provided phone numbers for individuals who test positive and will contact these individuals to determine locations that require cleaning.
  • To perform contact tracing to identify members of the UNC-Chapel Hill community who are believed to have had meaningful exposure in accordance with CDC guidelines. The appropriate contact tracing team will be notified of individuals who test positive through the asymptomatic screening program or who have consented to contact training after being tested by their physician.
  • To monitor areas where gatherings are estimated to exceed public health density guidelines. Campus Safety will be provided reports for investigation and assessment of risk reduction opportunities.
  • To review, evaluate and improve the quality, efficiency and performance of services that we provide to you.
  • To manage the data collection systems and to generate dashboard reports. UNC-Chapel Hill staff who are managing the databases and generating dashboards will have access to data systems and are required to limit their access to the underlying identified data in accordance with University requirements for student and employee data.
  • To perform research activities. Before we use or disclose your information for research, the research project must comply with applicable laws and regulations and obtain approval through a specialized review process. We may also contact you to see if you are interested in participating in research.
  • As otherwise permitted by law or to comply with any court order, law or legal process, including to respond to any government, regulatory, or law enforcement request.

Protecting Your Information.
The databases storing the COVID-19 Campus Safety information are configured in accordance with University requirements for Sensitive Information. Recipients of individual reports are expected to manage the information as required for Tier 2 and Tier 3 student and employee data. Information in the databases will be de-identified and/or deleted once the information is no longer needed for the Program. We have also hired third parties to perform certain services on behalf of the University, including data storage and interface reporting to the State. When we hire companies to perform these services, we may disclose your information to these companies so that they can perform the job we have asked them to perform. To protect your information, however, we require the third parties appropriately safeguard your information in accordance with University requirements for Sensitive Information.

Changes to this Statement.
This statement may be updated periodically to reflect changes in the Program or our privacy practices. Updated versions will be posted to this site.

Questions
If you have any questions about privacy, contact privacy@unc.edu. If you have questions about the Carolina Together COVID-19 response, you can submit questions here.