(Updated 24th June 2018)
About us - The Controller
Health Fabric is the trading name of Health Companion Ltd and provides technology for health and wellness monitoring services.
Health Companion is incorporated in England and Wales with company number 9727651 and whose registered office is at Eleven Brindley Place,2 Brunswick Square, Birmingham, West Midlands, B1 2LP (Health Companion, we, us and our).
Health Companion Limited, registered on the Data Protection Register with registration number ZA146919.
We are committed to protecting and respecting your privacy, Information Governance is about setting high standards for the handling of information and giving organisations the guidance to achieve those high standards in order to maintain confidentiality and the security of personal information. By adhering to IG, good practices in relation to information governance are established and this helps us to be consistent and compliant in the way that we handle your information.
1.1.2 MyHealthFabric mobile application software (App) available on our Website or hosted on other websites (each an App Site), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device); and
1.2 This policy sets out the basis on which personal data, sensitive personal data and other information (Personal Information) collected from you, or provided to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your Personal Information and how we will treat it
2. PERSONAL INFORMATION WE MAY COLLECT FROM YOU
2.1 We may collect and process the following Personal Information about you:
2.1.1 Personal Information you give us: You may give us Personal Information about you by filling in forms on the App Site and the Services Sites (together, Our Sites), or by corresponding with us. This includes, without limitation, information you provide when you register to use the App Site, download or register the App, subscribe to and / or use any Services. If you contact us, we may keep a record of that correspondence;
2.1.2 Personal Information we collect about you and your Device: Each time you visit one of Our Sites or use the App we may collect the following information:
(a) technical information (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);
(b) information stored on your Device, including:
(i) contact information but only when you wish to import a contact from mobile phone’s address book; and
(ii) photos and videos if you wish to use them as part of a care plan; and
Other API’s and services which you are notified by the respective apps stores from google and apple once the application has been downloaded
(c) details of your use of our App or your visits to any of Our Sites including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
2.1.3 Personal Information about your location: We may also use GPS technology to determine your location from time to time. Some of our location-enabled Services require your Personal Information for the feature to work. If you wish to use the particular feature, you will be asked to consent to your Personal Information being used for this purpose.
2.1.4 Personal Information we receive from other sources and entered by yourself: We work closely with third parties such as your GP, clinicians, hospitals, clinics, National Health Organisations, private healthcare organisations and providers and other third parties involved in the provision of your healthcare (Healthcare Professionals) and your Personal Information may be made available on the App by them with your consent and entered into the app by yourself. This Personal Information may include without limitation, your name, date of birth, address, e-mail address, telephone number, religious beliefs (where referred to in your medical records), physical and mental health details, details of medical allergies, ailments, conditions, prognoses, medicines, treatments, test results, personal descriptions, X-rays and photographs; and any other information entered by you directly. You are responsible for entering, managing and updating this information.
2.1.5 Unique application numbers: when you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
3. USES MADE OF THE INFORMATION
3.1 We use information held about you to enable the App to:
3.1.1 create a centralised view of your healthcare data which requires the integration of information from multiple disparate systems used by Healthcare Professionals with the ability to access and share information with you;
3.1.2 access your health records, medications, test results, book appointments and re-order medication directly with your GP practice;
3.1.3 make use of digital personalised care planning, giving you the control to manage your own health goals and monitor actions;
3.1.4 enable integration with Healthcare Professionals allowing you, persons authorised by you and your clinical team to make use of remote monitoring;
3.1.5 make use of diary management which encompasses the ability to log healthcare measurements, mood and wellbeing, appointments and tasks;
3.1.7 be signposted to resources and services according to locality and long term conditions;
3.1.8 provide Customer participation feedback to improve the provision of healthcare;
3.1.9 use integrated communication channels including videoconferencing functionality;
3.1.11 interact with your GP practice and act as the gateway for other Healthcare Professionals or Health Coaches to monitor progress;
3.1.12 put you in touch with Healthcare Professionals or Health Coaches;
3.1.13 provide you with care plans; and
3.1.14 provide you with access to a library of care plans that can be downloaded and personalised.
3.2 The App has the functionality to monitor App usage patterns. The ability to analyse a range of data points picked up gives us an informed view on what is working for Customers, it allows us to identify those Customers requiring a greater amount support and is used to enhance the way that care is commissioned to different demographics.
3.3 We do not disclose information about identifiable individuals to our advertisers, but we may provide them with anonymous aggregate information about our users (for example, we may inform them that 200 men aged under 25 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, men in EC1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
4. DISCLOSURE OF YOUR PERSONAL INFORMATION
4.1 We may disclose some or all of your Personal Information we collect from you when you download or use the App to the following third parties:
4.1.1 Healthcare Professionals or Health Coaches (as defined at clause 2.1.4 above); and
4.1.2 parties involved in the provision of Health Fabric data storage, data restoration, cloud, backup, disaster recovery, service level support and migration (Health Fabric Support Services).
4.2 In addition, we may disclose your Personal Information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
4.3 We may also disclose your Personal Information to third parties:
4.3.1 in the event that we sell or buy any business or assets, in which case we may disclose your Personal Information to the prospective seller or buyer of such business or assets;
4.3.2 if Health Fabric or substantially all of its assets are acquired by a third party, in which case Personal Information held by us about our users will be one of the transferred assets;
4.3.3 if we are under a duty to disclose or share your Personal Information in order to comply with any legal or regulatory obligation or request including, without limitation, the following;
(a) births and deaths - National Health Service Act 1977;
(b) notifiable communicable diseases - Public Health (Control of Diseases) Act 1984;
(c) poisonings and serious accidents at the work place - Health & Safety at Work Act 1974;
(d) a duty to disclose in accordance with any applicable child protection procedures;
(e) drug addicts - Drugs (Notification of Supply to Addicts) Regulations 1973;
(f) road traffic accidents - Road Traffic Act; and;
(g) prevention / detection of a serious crime e.g. terrorism, murder - The Crime and Disorder Act 1998
4.3.5 in order to protect the rights, property or safety of Health Fabric, our users or others. This includes exchanging information:
(a) for the purposes of fraud protection and credit risk reduction;
(b) where the subject's life may be in danger, or cases in which such a person may not be capable of forming an appropriate decision;
(c) to protect children and vulnerable adults from abuse;
(d) where there is serious danger to any persons, where the rights of others may supersede those of the subject, for example a risk to children or the serious misuse of drugs;
(e) where there is a serious threat to Healthcare Professionals, staff or other persons;
(f) where there is a serious threat to the community; and
(g) in other exceptional circumstances, based on professional consideration and consultation.
5. WHERE WE STORE YOUR PERSONAL DATA
5.1 UK based personal Information will not be transferred to, stored or processed at, a destination outside the European Economic Area except where compliance protocols are in place for the transfer of that Personal Information and the receiving country has an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of that Personal Information.
5.2 All information you provide to us is stored on secure servers.
5.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to Our Sites and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
5.4 We may collect and store Personal Information on your Device using application data caches, browser web storage and other technology.
5.5 Certain Services include interactive features such as social networking, chat room or forum features. Please ensure that when using these features that you do not submit any Personal Information that you do not want to be seen, collected or used by other users.
6. YOUR RIGHTS
6.1 Under certain circumstances you have the right to 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 of your personal data, Right to withdraw consent.
6.2 You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your personal data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes when registering with us. You can also exercise the right at any time by contacting us using the contact details at clause 10 below .
6.3 All Customer data held by us is controlled by Healthcare Professionals or Health Coaches and you. The relevant Healthcare Professionals control the data they want to synchronise within the Health Fabric cloud.
6.4 Customer data will also need to be viewed by our specialist operators who review provide health monitoring services
6.5 In the event that you no longer wish to use the App, your data will be anonymised until it is later deleted, so that as an individual you will no longer be associated with, or identifiable from that data. We shall have no obligation to retain your data.
6.6 Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or the Services are advertised). If you follow a link to any of these websites, 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 Information that may be collected through these websites or services. Please check these policies before you submit any Personal Information to these websites or use these services.
7. HOW WE COLLECT YOUR DATA
We use different methods to collect data from and about you including through interactions which include:
Interactions of a direct nature for example by filling in forms or by corresponding with us by post, phone, email, web app or otherwise. This includes personal data you provide when you:
apply for our products or services;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us some feedback.
Automated technologies or interactions. As you interact with our website, or app we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies
8.2 The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services.
10. CONTACT DETAILS
Full Name of Entity : Health Companion Limited, Eleven Brindley Place, 2 Brunswick Square, Birmingham, West Midlands, B1 2LP
Name or title of data privacy manager: Beth Dooley
Email : info@healthFabric.co.uk