Privacy Notice CLEAR Dementia Care © App
The information referred to in this document is owned by the Northern Health and Social Care Trust (Northern Ireland). The Northern Health and Social Care Trust comply with Caldicott Principles and have an appointed Personal Data Guardian. We house our data on the Amazon Web Services (AWS) Platform. The personal information that we process about you is governed by the Data Protection Act 2018 and the General Data Protection Regulation (GDPR).
Data collected by the app will not be shared or processed for any other reason than outlined in this policy.
- How we use your information
To operate and improve the app
- To enable you to use the apps features
- To establish and maintain your account
- To perform statistical analysis about use of the app
- We will never identify individual users of the app. Statistical analysis of app usage will allow us to see what pages are most used/visited by our users.
- To understand basic information on those who use the app – the following information can be provided voluntarily by app users on downloading the app. The information submitted by app users below is not stored with any information that could identify the app user.
– age range – the reason for collection of this information is for the purpose of research and analysis on the age range of app users.
– carer role – the reason for collection of this information is for the purpose of research and analysis of the role of app users.
– gender – the reason for collection of this information is for the purpose of research and analysis of the gender of app users.
- Research and analysis of the above information will be considered when updating and improving the app. We may also use data collected regarding your age/carer role/gender for research purposes.
If you feel there has been a breach of your data, you can complain to the Information Commissioners Office, or lodge a complaint with your local data protection authority, or local supervisory authority. Details of the Information Commissioners Office are as follows, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF. Tel: 0303 123 1113.
- What kinds of information are being processed?
The primary uses of this App are to provide information to users and to enable users to create a record of behaviour. We are able to obtain information on the number of app downloads by country. Information on the location of app users is not obtained.
On first login, users are asked to voluntarily provide information on care role, age range and gender.
To use the behaviour chart function, app users must create a login. The purpose of creating this login is to enable the user to gain full functionality of the app – including back up of their behaviour charts to cloud storage. In order to create a unique identity, app users must create a password and provide their email address and telephone number.
User data is encrypted between their device and host storage.
Data provided by app users will not be used to contact app users and will never be shared or sold.
The user has the opportunity to delete data. Deleting an account removes email address, telephone number and password from our storage and behaviour charts will no longer be identifiable.
This app has very limited data or privacy risk if accessed by children. Voluntary information provided on first downloading the app does not identify any individual user. As outlined above, an email address, telephone number and password are provided by users if they choose to use the behaviour chart function (an optional function). Should the information by provided by a child without parental consent, the user can delete their data as detailed in the paragraph above. That information is never sold, shared or used to make contact with app users.
App users have the following rights:
- To access personal data
- To rectify personal data
- To restrict use of personal data
- To object to processing of personal data
- To withdraw consent for use of personal data
- To portability of personal data
- To exercise their rights by contacting email@example.com. Sentireal will respond to any requests within 30 days.
App users are not subject to any decisions based solely on automated processing.
The developers intend to ensure principles of data minimisation. We only collect personal data we actually need for the purposes specified in this policy. We do not hold more data than what is needed to fulfil those purposes.
- Retention of information
Information will be retained for 7 years.
App users have the option of deleting their account along with the backup of their behaviour charts. Deletion of account means email, phone number and password.
- The lawful basis for processing
The lawful basis from processing this information is Consent.
- Non-disclosure of your information
The Northern Health and Social Care Trust take privacy seriously. The information you provide as outlined (in section 2 above) will not be used other than for the purposes outlined in section 1. All staff have a legal duty to keep your information safe and confidential and are aware of their responsibilities in regards to your privacy. Any organisation we share information with is also bound by legislation to ensure information is handled correctly. In compliance with legislation the Trust has a range of measures in place to protect paper and electronically held information.
The Data Protection Officer for the App is Nicola Lyons, Northern Health and Social Care Trust.
General queries can be sent by email to CLEAR.DementiaCare@northerntrust.hscni.net