Data Protection and Privacy Policy

Last updated 3rd August 2018

References to “we”, “us”, “you” or “our” in this Privacy Policy are references to TINY MEDICAL APPS, a company limited by guarantee registered in England and Wales, registered company number: 10051596.

Definitions

TINY MEDICAL APPS

means Tiny Medical Apps Ltd, a registered Company.

GDPR

means the General Data Protection Regulation.

Responsible Person(s)

means the TINY MEDICAL APPS Executive Directors

Register of Systems

means a register of all systems or contexts in which personal data is processed by TINY MEDICAL APPS.

 

1. Who we are and how to contact us

1.1 TINY MEDICAL APPS builds and supports health care solutions using agile methodolgy and co-design principles.

1.2 The Data Controller for our products is Tiny Medical Apps Ltd, Canterbury House, 1 Royal St, Lambeth, London SE1 7LL (Registered with ICO).

1.3 You can contact us by writing to support@tinymedicalapps.com.

2. Data protection principles

2.1 TINY MEDICAL APPS is committed to processing data in accordance with its responsibilities under the GDPR.

2.2 Article 5 of the GDPR requires that personal data shall be:

a) processed lawfully, fairly and in a transparent manner in relation to individuals;

b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;

c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;

e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and

f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”

3. Information about you

2.1 We will collect personal information from you when you request information from us, when you view and interact with pages on our website, when you join one of our hosted applications such as Health Passport or Boost.

2.2 The information we collect may include your first name, last name, date of birth, sex, email address, telephone number, sensitive health data if using Health Passport (more information about privacy on that platform is available here). We may also ask for some additional, non-personal information.

2.3 TINY MEDICAL APPS shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

4. Lawful purposes

4.1 All data processed by TINY MEDICAL APPS must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests ( see ICO guidance for more information ).

4.2 TINY MEDICAL APPS shall note the appropriate lawful basis in the Register of Systems.

4.3 To ensure its processing of data is lawful, fair and transparent, TINY MEDICAL APPS shall maintain a Register of Systems, which shall be reviewed annually.

4.4 Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.

4.5 Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in TINY MEDICAL APPS’s systems.

5. Our use of this information

5.1 Your personal information will only be used to process your requests, process and manage your user activity on one of our hosted platforms, facilitate navigation of our website, inform you of the existence of or a change to our activities and services, process a contract, and to provide you with information relating to our services and all other relevant information which we think you may be interested in.

5.2 We will not share your personal information with any third-parties without your prior authorisation, unless current regulations require such data to be communicated, including upon request from the legal authority in accordance with legislative provisions.

5.3 TINY MEDICAL APPS shall take reasonable steps to ensure personal data is accurate.

5.4 Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

6. Retention of Personal Data

6.1 Personal data collected by TINY MEDICAL APPS is kept for a limited period until the purpose for which it was collected has been fulfilled, and provided you do not exercise your rights as detailed below.

6.2 To ensure that personal data is kept for no longer than necessary, TINY MEDICAL APPS shall put in place an archiving policy for each area in which personal data is processed and review this process annually.

6.3 The archiving policy shall consider what data should/must be retained, for how long, and why.

7. Your Rights

7.1 Provided you can prove your identity, you have at all times the right to access and to rectify your personal data. You also have the right to contest, for a legitimate reason, the processing of these data and their communication to third parties.

7.2 Requests made to TINY MEDICAL APPS shall be dealt with in a timely manner.

7.3 TINY MEDICAL APPS can contest any requests that are clearly abusive, including but not exclusively in terms of their number, or their repetitive or systematic nature. These rights can be exercised by writing to support@tinymedicalapps.com . Users are informed that telephone requests will not be accepted.

8. Security

8.1 We will take reasonable precautions to prevent the loss, misuse or alteration of information you give us.

8.2 Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.

8.3 When personal data is deleted this should be done safely such that the data is irrecoverable.

8.4 Appropriate back-up and disaster recovery solutions shall be in place.

8.5 Communications in connection with TINY MEDICAL APPS may be sent by e-mail. For ease of use and compatibility, communications (other than payments where applicable) will not be sent in an encrypted form unless you require it and provide the certification to enable us to communicate with you in that way. E-mail unless encrypted is not a fully secure means of communication. Whilst we endeavour to keep our systems and communications protected against viruses and other harmful effects we cannot bear responsibility for all communications being virus-free.

8.6 You are responsible for protecting the security of your membership account, your user name and password. If you believe that a third party knows or has changed your password, or that a third party can access the email address linked to your membership account, you are requested to inform TINY MEDICAL APPS without delay by writing to support@tinymedicalapps.com

9. Breach

9.1 In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, TINY MEDICAL APPS shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the relevant supervisory authority.

10. Cookies

10.1 If cookies are used they will only be used to assist the purposes set out in this privacy policy, but cookies will not be used if we do not consider them to be necessary.

11. Other information

11.1 If you would like us to correct or update any information, or if you would like information deleted from our records, then please email us at support@tinymedicalapps.com

11.2 This privacy policy may be updated from time to time, so please check it periodically.

11.3 The TINY MEDICAL APPS website may host links to third party sites. If so, TINY MEDICAL APPS recommends that you read these third-party sites’ privacy policies carefully.

11.4 Links within our website to other websites are not covered by this privacy policy.

END OF POLICY