Apps and Portals
BSOL Care Homes Communications App
Privacy notice for the BSOL Care Homes app.
BSOL Care Homes Communications App Privacy Policy
This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when you use our our web-based “BSOL Care Homes Communication App”. It also outlines your Privacy Rights and how the law protects you.
We take privacy and the protection of personal and sensitive information seriously and are committed to protecting your data and complying with the data regulations to their full extent. Our Privacy Policy explains how we use and protect your personal information, to show that we are adhering to the UK General Data Protection Regulation and the Data Protection Act 2018.
Birmingham Community Healthcare NHS Foundation Trust, (BCHC) is the Data Controller for the information being processed, unless otherwise stated,and is registered with the Information Commissioner’s Office (Z243363X). You can find us on the Information Commissioner's register searching for us by using our registration number.
BSOL Care Homes Communications App has been commissioned by the Birmingham and Solihull Clinical Commissioning Group (BSOL) and is made available through Schappit Ltd (trading as Piota Apps), who process data on behalf of the Trust in order to support the design, customisation and facilitate the provision of information found on the app. BCHC have a written contract in place directly with Schappit Ltd.
Your data will be processed on the app in line with the UK General Data Protection Regulation, (GDPR) and UK Data Protection Act 2018 for the “Purpose” of delivering a communications platform for access to health and care information and employee resources.
Please read this privacy policy carefully as you will be asked to confirm you have read and understood the processing operations and legal basis in which we will use, share, secure and retain your personal data.
The Term "you" and "your" refers to the registered users of Care Homes Communications App.
Personal Data we collect and process
In order to ensure that you can register, access the platform, and in order to easily identify you on the platform, personal data is collected as below:
- First and Last Name
- Email Address (work or personal)
- Telephone number (work or personal)
- Any information which you submit when completing a form or a survey on the App.
This applies to BCHC staff, any participating organisation, employees, and members of the public that download the app.
Please note that:
- Registration is only required to access any controlled App content. The majority of content published will be without restriction.
- Unique device identifiers such as device manufacturer serial numbers (e.g. IMEI, MAC, ICCID, MEID, CDN numbers) are never collected by the App; and
- No Cookies are used on the app, therefore your activity before and after you visit the App is not tracked by the App.
Piota Device Token (the “PDT”) as used by the App
Schappit does not use cookies as highlighted above and instead use a proprietary PDT ‘token’ or ‘identifier’ which is much more limited in its scope and cannot be used to track users, suggest adverts, extract personal data or for other malign purposes performed by website cookies.
(a) How the PDT is used:
(i) A PDT is placed in the Application Sandbox (an isolated zone designed to hold only certain files) of the device onto which a Piota app has been downloaded;
(ii) The PDT reads and stores only the device’s generic make and model
(iii) This information is used for the following purposes only:
A. Notifications. To send notifications to eligible devices
B. Content. To control access to articles on the App to designated users.
C. Analytics. To record which pages of the app are visited, so anonymised and aggregated analytics data can be compiled
(b) The PDT has no ability to ‘see’ or track End User activity on the device beyond activity on the App. If the End User deletes the App from their device the PDT is permanently destroyed.
You can read more information about this in the Data Processor’s Privacy Policy. Privacy & Cookies Policy – Piota App | Piota Piota Apps.
The purpose of processing
The BSOL Care Homes Communications App will process personal data in order to deliver and administer resources for educational and information purposes. The purpose of processing is to aid the Data Controller to determine, evaluate and support the development of the app.
How your data will be processed
Your personal data is used to allow you to log in and access the resources provided on the app.
The processing operations will involve but are not limited to:
- Enable BCHC to undertake communication and administration tasks in relation to the management of the app
- Disseminate information about BCHC and relevant organisations’ activities to you and other App users, e.g. updating you in relation to activities, events and news bulletins relating to the organisations and providing contacts details for you to use
- Providing feedback to BCHC through surveys
- To provide technical support in relation to your use of the App and troubleshooting.
Retaining your personal information
The app’s content management system (CMS) will only store as much information about you as is required, and we will request secure destruction of any personal information about you when it is no longer of use or if you log a request for deletion.
We will keep your information for as long as you are using the app and your data will be deleted after 60 days if you log a request for deletion by emailing bchc.informationgovernance@nhs.net.
If we terminate the contract with our Data Processor, Schappit Ltd we will request deletion of any data on contract termination and the deletion will occur within 60 days of the request and will be confirmed by Schappit Ltd to us.
Sharing your information with others
In relation to the data collected and taking precautions to maintain the security of such information including redacting as much as possible of the data, BCHC may share this information with:
- Schappit’s data centre management company and web hosting partner;
- Schappit’s technical support ticketing system;
- Schappit’s third party developers;
We work with the above parties to store the information on BSOL Care Homes App and manage the system. These organisations will only be provided with access to your information in order to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures.
We will share your information with others where we are required to do so by law.
We will never sell your information to anyone, or share it in a way not described in this privacy policy.
Legal basis to process your data
We hold and process your personal data for the following legal basis:
For BCHC employees
Processing is necessary for the performance of contract in which the employee (data subject) is subject or party to
Processing is necessary for the performance of a task carried out in the public interest.
and
For members of the public and other participating organisations
Through consent provided by you at sign up. which you can withdraw at any time.
How we keep your data safe
Access to your personal information is restricted to BCHC app administrators.
BSOL Care Homes App data is stored in the UK, hosted by Rochen Ltd as a data processor.
When we choose our data processors we ensure that they provide us with sufficient guarantees about their security measures and we have written contracts in place that require our Data Processors to have appropriate organisational and technical measures in place to protect your data.
BCHC have carried out due diligence to ensure that technical safeguards, such as firewalls and antivirus software are used to help ensure that your information is kept safe and only disclosed to people who are authorised to view it. Our Data Processors have measures in place to ensure the confidentiality, integrity and availability of data.
Your rights and access to your data
You have the following rights and BCHC have a system in place to ensure you can exercise your rights:
- To be informed
- Access data
- Rectification of data
- Erasure of data
- Restrict processing
- Port data
- To object to processing
- Automation decision making and profiling – (this processing does not take place in this service)
You will be able to log into BSOL Care Homes App in order to access or update the information we hold about you using your username and password.
You can also make a request for a copy of this information, make a request for the correction of any mistakes, or you can delete the app at any time and log a request for deletion of your data by emailing bchc.informationgovernance@nhs.net.
Contact Information
You can contact BCHC if you would like more information on your rights, how we process and share your data. You can raise your concerns or complaints by contacting our Data Protection Officer (DPO).
As a public authority, the Trust is required to appoint a DPO, whose role it is to ensure that the Trust has in place appropriate mechanisms and procedures to protect your information and to ensure that personal data is processed lawfully within the Trust.
The Trust’s DPO is Michael Morgan-Bullock, Head of Legal Services, who may be contacted at the following details:
Email: bchc.dpo@nhs.net
Post: Data Protection Officer, Information Governance, Birmingham Community Healthcare NHS Foundation Trust, 3 Priestley Wharf, Holt St, Birmingham B7 4BN.
You also have the right to complain to the ICO if you are unhappy with how process your data.
The ICO's address is:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113