ICSThub mobile application Privacy Policy

Welcome to ICSThub’s privacy policy. We respect your privacy and are committed to protecting your personal data.

Please note that a reference to “you” in this privacy policy may also mean a reference to your child/patient of which you have care of.

This privacy policy (together with our end-user licence agreement (EULA), often referred to as our Terms and Conditions,  and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of:-

●      TRACHEShub [and any updates or supplements to it] mobile application software (App) available on our site (App Site) once you have downloaded it onto your mobile telephone or handheld device.

●      Any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites), unless the EULA states that a separate privacy policy applies to a particular Service, in which case that privacy policy only applies. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

The App is a lifestyle management tool and does not provide personalised medical advice. Use of the App is not a substitute for medical advice. You should not rely on the App to take any action or refrain from taking any action in a manner which is inconsistent with medical advice. If you are in any doubt, you should seek medical advice before taking any action or refraining from taking any action in reliance on the App.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

Please also use the Glossary (section 9 below) to understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. GLOSSARY

1.                 IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how The Institute of Clinical Science and Technology Ltd collects and processes your personal data through your use of this App, including any data you may provide through this App.

CONTROLLER

The Institute of Clinical Science and Technology Ltd is the controller and responsible for your personal data (collectively referred to as “The Institute of Clinical Science and Technology Ltd “, “we”, “us” or “our” in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: The Institute of Clinical Science and Technology Ltd

DPO: Christopher Davies

Email address: chris.davies@clinicalscience.org.uk       

Postal address: The Institute of Clinical Science and Technology, 50 Cathedral Road, Cardiff, CF11 9LL

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. This version was last updated on 19^th September 2023. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact Data. Please check these policies before you submit any personal data to these websites or use these services.

2.                 THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). There are certain types of more sensitive personal data (known as special category data) which require a higher level of protection, such as information about a person’s health. We will ensure that the personal data that we collect is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

●                  Identity Data includes first name, last name, username or similar identifier, date of birth and gender.

●                  Contact Data includes address, collection address, email address, telephone numbers.

●                  Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), time zone setting. 

●                  Profile Data includes your username and password, preferences (such as the education that you are interested in viewing), feedback and survey responses.

●                  Usage Data includes details of your use of our App or your visits to any of our sites and the resources that you access.

●                  Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We will also collect, store and use the following more sensitive types of personal information:

●      Information about your health (collectively referred to as Health Data), including:

●                  details about your medical condition and how this affects you (i.e. the medication you take, or tracheostomy tube you use);

●                  test measurements;

●                  the severity of your symptoms when you feel unwell;

●                  information you provide when you complete health surveys and questionnaires via the App;

●                  any health services you may have/ have not received;

●                  any other relevant treatments or therapies that you have received.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

3.                 HOW IS YOUR PERSONAL DATA COLLECTED?

We will collect your personal data in the following ways:

●      Information you, or an authorised carer, give us. This is information you consent to giving us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence. We will also collect your personal data when you respond to questionnaires, when visiting a healthcare professional.

●      The app contains a feature, to support people with additional needs, where a carer can be invited to contribute to their app use. This function is with a user explicit consent and can be withdrawn with immediate effect within the app. Any action taken by an invited carer is recorded and visible to ensure transparency and safeguarding.

Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy on our website for further details. [The data that is captured through your interactions with TRACHEShub is stored securely in external host storage and is only accessible to accredited administrative users with specific access permissions. Data in transit between webpages and the data store are fully encrypted in transit, in line with best practice encryption methodologies to minimise the risk of interception.]

COOKIES

We use cookies to distinguish you from other users of the App, App Site, the distribution platform (App store) or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies please see the cookies policy on our website.

4.                 HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

●                  Where you have consented before the processing.

●                  Where we need to perform a contract, we are about to enter or have entered with you.

●                  Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

●                  Where we need to comply with a legal or regulatory obligation.

Use the Glossary in Section 9 below to find out more about the types of lawful basis that we will rely on to process your personal data.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION

We will only process special categories of personal information (such as your Health Data) when we have your explicit consent to do so. The situations in which we will process your health data are listed below:

●      We will aggregate your Health Data for research purposes. In this situation, although the data is derived from your health data it will not be considered as personal data in law as it will not directly or indirectly reveal your identity.

●      We will have access to all the Health Data that you add to the app. This enables us to address any technical or data entry problems, should they arise.

DISCLOSURES OF YOUR PERSONAL DATA

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data and How we use particularly sensitive personal information above:

●                  Internal Third Parties as set out in the Glossary.

●                  External Third Parties as set out in the Glossary.

●                  Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5.                 INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the UK.

6.                 DATA SECURITY

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

7.                 DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available upon request from us by contacting us.

In some circumstances you can ask us to delete your data: see Your Legal Rights in Section 8 below for further information. You can delete your data by going into the settings section of the app and clicking on ‘permanently delete account’. This will erase all of your personal data.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

8.                 YOUR LEGAL RIGHTS

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

●                  Request access to your personal data.

●                  Request correction of your personal data.

●                  Request erasure of your personal data.

●                  Object to processing of your personal data.

●                  Request restriction of processing your personal data.

●                  Request transfer or your personal data.

●                  Right to withdraw consent.

You can exercise any of these rights at any time by contacting us at support@icst.org.uk

9.                 GLOSSARY

LAWFUL BASIS

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

INTERNAL THIRD PARTIES

Other companies in the group acting as joint controllers or processors and who are based in the UK and provide IT and system administration services and undertake leadership reporting.

EXTERNAL THIRD PARTIES

●      Service providers acting as processors who provide IT and system administration services.

●      Software/developer providers to support app functionality.

●      Information storage providers (AWS).

●      Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

●      HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

●                  Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

●                  Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

●                  Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

●                  Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

●                  Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

 (a)    if you want us to establish the data’s accuracy;

 (b)    where our use of the data is unlawful but you do not want us to erase it;

 (c)     where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

 (d)    you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

●                  Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

●                  Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.