Last updated: December 2021
This privacy policy statement describes the privacy and processing arrangements for the Healthier Together app commissioned by your local NHS Integrated Care System hereafter referred to as simply "NHS" and provided by the app developer.
We publish this policy to ensure everyone understands what happens to the data they enter into the Healthier Together app. We treat all information in line with our legal responsibilities and recognise best practice standards and processes.
We respect the privacy of all who use the Healthier Together app.
References to “Healthier Together app”, “we” and “us” in this privacy policy refer to the joint data controllers for the Healthier Together app commissioned by the NHS and provided by the app developer.
The following legal bases set out in the General Data Protection Regulation (GDPR) and UK Data Protection Act 2018 allow your GP practice to use your information when you use the online consultation feature of the app:
Article 6 (1) (e) of the GDPR, which permits us to process your personal information that is necessary to provide a service which is in the public interest
Article 9(2) (h) of the GDPR which permits us to process your health information which is necessary for the provision of health treatment.
No personal data is collected or processed by the NHS or the app developer from the app. The data you choose to enter into the app is stored locally on your device and may not be accessed by a third party. We do not store any of the data you may enter on your device. The app is built so that any data you enter into it is encrypted and complies with all regulatory requirements to keep your data secure.
If enabled by your registered GP practice, the Healthier Together app allows you to submit an online consultation request. Because this service is online, your GP practice needs to ensure that they can provide you with a confidential and high-quality service. To do so, they need to properly identify you, accurately note both your request and their responses. If they were prevented from using this essential information, then they would be unable to provide the service securely and confidentially.
Information which is needed for this service is not collected by the local NHS commissioner or the app developer.
Healthier Together will share the information held in your profile including name, sex, date of birth and phone number with your GP practice only when you submit an online request. In addition, the symptoms that you have selected and any additional information entered is collectively sent securely to your GP practice only who will process this information as per their policies.
We use Google Analytics to collect and process anonymised data about how the app is used such as number of users using the app and pages visited within the app and length of visit. We store limited information to support push notifications. This may include your unique device identifier, sex, age (based on month and year of birth only) and your registerd GP practice. More information about how Google processes this data can be found here.
We respect the privacy of all who use the Healthier Together app prototype. However, you will also need to consider your privacy in the context of your family, friends and colleagues. When thinking about your responsibility for the security of how you access the Healthier Together app, points for you to consider include:
1. Are you happy for any of them (your family, friends and colleagues) to be able to access your data?
2. If you are and you provide them with access to your data the people you give access to will be able to see everything you can see and do everything you can do.
3. If you choose not to share your data with family, friends and colleagues you will also need to consider:
a. How you keep your device credentials e.g. password, PIN or unlock pattern secure.
b. If there is shared access to the equipment used to access the Healthier Together app what steps you can take to ensure that your data is not visible or accessible to someone who uses the shared device after you. Steps you can take include:
i. Not using shared devices.
ii. Keeping your device password, PIN or unlock pattern private.
c. You should also consider who can also view your data while you access the Healthier Together app.
The data is stored on your device only so be aware that in the absence of a full backup, if you change or lose your device you will lose the data you have entered in the app.
We will use the anonymous information from the app analytics to understand how the app is used so we can consider improvements to the app’s design and content.
It is processed and stored within the United Kingdom only.
The information you entered in your device is kept in an encrypted format on your device only for as long as you keep the app. The data we store to support push notifications is kept on our servers for a period of 12 months following your last use of the app and then automatically deleted. All data is deleted when you delete the app from your device and our servers. Your GP practice sets the retention periods for your information when you submit an online request to them as per their polices. Please visit your GP practice website to learn more.
If you have a complaint please contact your local NHS commissioner in the first instance. The local NHS commissioner's Data Protection Officer can be contacted via their website.
You also have the right to complain to the Information Commissioner. The Information Commissioner can be contacted at:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Or via: https://ico.org.uk/
Or by telephone on: 01625 545 745
We may change this privacy policy statement at any time. Where substantial changes are made to the privacy policy we will update the app and advise users of the revised privacy policy for acceptance prior to accessing the updated app.
We have taken every care in the preparation of the content of this application, which is designed and provided for parents, carers and guardians. Every situation is unique and advice may change over time. You must therefore exercise your own judgement at all times.
Healthier Together does not warrant or guarantee the accuracy or completeness of the information provided in this application. Healthier Together also acknowledges the use of content taken from other sites and claims no credit for the creation of it.
If you have any doubts or queries as to whether advice/content is accurate or applicable to your situation you may contact us via the Feedback section in the app. Please note this feature should not be used to seek medical advice. Please do not share any personal information.
We accept no responsibility or liability, which may arise from the use of any of the features or information of this app. Under no circumstances will Healthier Together be liable for any loss or direct, indirect, incidental, special or consequential damages caused by the reliance of features or information of this app.