https://tech.newstatesman.com/gdpr/open-rights-group-reports-nhs-test-and-trace-to-ico

Privacy campaigners have launched a legal challenge against the NHS Test and Trace scheme, claiming that it breaches GDPR. The Open Rights Group (ORG) has filed a complaint with the ICO and written to secretary of state Matt Hancock and others to demand answers. 

The ICO complaint is predicated on the fact that the NHS and PHE failed to carry out a data protection impact assessment (DPIA) before forging ahead with the scheme, despite GDPR calling for one in high risk data processing scenarios. The group argues the scheme qualifies as such because of its experimental nature, the sensitivity of the data collected, and its scale – which could impact millions of people.