It committed to provide this document to the ICO next week, saying: "Public Health England has taken careful steps to ensure that the NHS Test and Trace complies with its legal obligations and will publish the Impact Assessment on the NHS Test and Trace website, alongside the existing privacy notice, as soon as possible after consulting with the ICO."
The Open Rights Group has instructed Ravi Naik, legal director of the data rights agency AWO, who said: "Rushing out Test and Trace without following basic legal requirements is troubling.
The Open Rights Group argues that because Test and Trace is experimental, and processes data of a sensitive nature on a large scale, a DPIA was required before data processing started.
The complaint to the ICO relates to the failure by the NHS and Public Health England (PHE), which runs the Test and Trace programme, to conduct a Data Protection Impact Assessment (DPIA), which is required under the GDPR before processing of data in high-risk situations.
Open Rights Group has instructed lawyers to lodge a complaint with the UK's data watchdog over the rollout of the Test and Trace system because it says the system breaches the General Data Protection Regulation (GDPR).