1.1 We are committed to safeguarding the privacy of our web application users, mobile application users, and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our web and mobile application users and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 We may use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
1.4 In this policy, "we", "us" and "our" refer to Cambridge Digital Health Ltd, for more information please visit www.cambridgedigitalhealth.co.uk.
1.5 In this policy, “mobile application” refers to the Network Status mobile application and “web application” refers to the Network Status web application.
2.1 In this Section 2 we have set out:
2.2 We may process data about your use of the web and mobile application(s) and related services ("Usage Data"). The Usage Data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and navigation paths, as well as information about the timing, frequency and pattern of your web and mobile application and service use. The source of the Usage Data is our analytics tracking system. This Usage Data may be processed for the purposes of analysing the use of the web and mobile applications and services. The legal basis for this processing is our legitimate interest, namely monitoring and improving our applications and services.
2.3 We may process your name and email address ("Account Data"). The source of the Account Data is the information that you have added when you registered to use the application and related services or which your employer may have added when enrolling you to use the application and related services. Occasionally, we may need to contact some users to confirm account data and this can be done via email or phone call. The Account Data may be processed for the purposes of operating the web and mobile applications, providing our services, ensuring the security of related applications and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interest, namely the proper administration of the web and mobile applications and our business.
2.4 We may process your information included in your personal profile on our web and mobile applications ("Profile Data"). The Profile Data may include your name, email address, associated organisation details such as hospital, city location of the hospital and your job title. The Profile Data may be processed for the purposes of enabling and monitoring your use of the mobile application and related services. The legal basis for this processing is our legitimate interest, namely the proper administration of the web and mobile applications and our business.
2.5 We may process your personal data that are provided in the course of the use of our services ("Service Data"). The Service Data may include the date and time at which you have used the service, and the information that you have recorded about your unit or hospital. The source of the Service Data is what you have recorded on the web and mobile applications. The Service Data may be processed for the purposes of operating the web and mobile applications, providing our services, ensuring the security of the web and mobile applications and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our web and mobile applications and business.
2.6 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.7 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.8 Please do not supply any personal data to us unless we prompt you to do so.
3.1 A group of administrators in healthcare service may provide the system with your Account Data and will therefore have access to this data in the web and mobile app.
3.2 We may disclose your personal data to any member of our company insofar as reasonably necessary for the purposes, and on the legal bases set out in this policy. Information about our group of companies can be found at www.cambridgedigitalhealth.co.uk.
3.3 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.4 We may use anonymised aggregated summary of personal data to perform statistical analysis (including app usage data and the impact of app usage on NHS services).
3.5 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 We and our other group companies have offices and facilities in England, Scotland and Portugal. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from their website.
4.3 The hosting facilities for the mobile application are situated on the N3 server of the Cambridge University Hospital, in England. The European Commission has made an "adequacy decision" with respect to the data protection laws of this country. Transfers to this country will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from their website.
4.4 There is no anticipated need to transfer personal data to countries outside the UK and the EEA, however if this is required in the future a transfer will be protected by appropriate safeguards, namely the adequacy status of the receiving country as awarded by EU, or the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from their website.
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
5.4 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of significant changes to this policy by email.
7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The copy of your personal data may be subject to £10 administration fee.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection, but please do let us know in the first instance. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.11 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.12 You may exercise any of your rights in relation to your personal data by written notice to us using the form at www.cambridgedigitalhealth.co.uk.
8.1 This web application and mobile application is owned and operated by Cambridge Digital Health ltd.
8.2 We are registered in England and Wales under registration number 10274147, and our registered office is at Cambridge Digital Health, 320 Cambridge Science Park, Cambridge, CB4 0WG.
8.3 Our principal place of business is at the Cambridge Digital Health, 320 Cambridge Science Park, Cambridge, CB4 0WG.
8.4 You can contact us:
9.1 Our data protection officer's contact details are: Dr Oriane Chausiaux, Director.
For more information, visit http://www.cambridgedigitalhealth.co.uk/.