ASARM APPLICIATION PRIVACY NOTICE

The Activity, Sleep and Rest Monitoring App (ASARM) is provided by Manchester University NHS Foundation Trust (MFT), Oxford Road, Manchester, M13 9WL.

MFT acts as a Data Controller of your personal data provided in the use of ASARM which means that MFT is responsible for deciding how to hold and use this personal data. Consequently, references below to “The Trust”, “we”, “us”, or “our” relate to Manchester University NHS Foundation Trust as supplier of the App.

MFT is committed to protecting and respecting your privacy.

SCOPE OF THIS PRIVACY NOTICE

This notice (together with our "Terms of Use") applies to your use of:

the ASARM mobile application software (the "App") (available on a number of different App marketplaces (the "App Sites")), once you have downloaded or streamed a copy of the App onto your mobile telephone or other handheld device ("Device"); and

aspects of the Children’s and Adolescents Mental Health Service (CAMHS) (the "Service") accessible through the App.

This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. ‘Processing’ for the purposes of this notice covers a very broad range of activities, including using, transferring, storing and even deleting data.

Please read the following terms carefully to understand our views and practices regarding your personal data and how we will treat it.

For the avoidance of doubt:

By registering to use the App, or supplying data or information through the App, you acknowledge that you are aware of the collection, use and transfer of the relevant data and your personal data under the terms of this privacy notice (and the End User Licence Agreement).

You may use the Service and the App in order that MFT can help treat your diagnosis of chronic fatigue.

PERSONAL DATA WE MAY COLLECT IN RELATION TO YOU

You have been sent an invite to use the App for the purpose stated above using information that the Trust holds about you:

If you contact us, we may keep a record of that correspondence;

Information we collect about you and your Device. Each time you use the App we may automatically collect the following information:

USES MADE OF THE INFORMATION

We may use personal data we collect about you in the following ways:

Submitted Information: We will use information which you submit as part of registering to use the App in order to manage your account, to provide technical support, to contact you so as to notify you regarding any important updates relating to the App, to answer queries you might raise regarding the App and for our own internal administrative purposes. To help us to verify your identity where appropriate by cross-checking against our records (to help keep your information secure).

To help treat your diagnosis of Chronic Fatigue: The purpose of the App is to collect data on your different activity states (activity, rest and sleep) to enable your clinician to understand your energy expenditure on a daily, weekly and monthly basis and to use this information to recommend new energy expenditure targets based on disease and treatment progression.

Device Information: We will use this information to help ensure that ASARM presents the correct version and data for your Device.

Log Information: this is stored for security and audit purposes and to ensure that we are able to support your use of ASARM.

For security and safety purposes: We will monitor activity in order to help protect our users from security threats and to detect if users are trying to misuse any element of the App or to use it in an unauthorised manner. MFT may also use your contact information in order to alert you to any relevant security issues or safety concerns of which The Trust becomes aware.

To statistically analyse user behaviour and activity: This includes how many patients use the App, how many times they enter activity data.

We will only use your personal data for the purposes for which we collected it. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

BASIS ON WHICH WE PROCESS YOUR PERSONAL DATA

The Trust relies on Articles 6.1(e) (Public Task and 9.2(h) Delivery of Health Care for processing the information that you provide to us through the App.

DISCLOSURE OF YOUR INFORMATION

MFT will only use the information you provide to inform your treatment and will not disclose any of it outside of the organisation. The information that you provide will become part of your medical record.

HOW AND WHERE WE STORE YOUR PERSONAL DATA

MFT uses strict procedures and security features designed to prevent any unauthorised or unlawful access to the personal data which it controls.

Personal data which The Trust holds in relation to you will be stored securely on our premises and (where relevant) at the premises of third party service providers operating under contract to The Trust. Your personal data may also be stored in secure data centres located within the United Kingdom.

All Personal Data will be encrypted (using industry standard methods) when being transferred from your Device to the relevant data centre.

Where The Trust has given you (or where you have chosen) a password that enables you to access the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We will retain a record of your personal data in accordance with relevant law and where we have a reasonable business need to do so, for example, in order to manage our relationship with you.

In line with any legal and regulatory requirements or guidance in respect of retention periods.

As noted above, we may use service providers to help us run App or Service. However, it is our responsibility to ensure that if we use any such service provider that we ensure that we have the necessary safeguards in place. We may also independently audit these service providers to ensure that they meet our standards.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of any data transmitted to The Trust; any transmission that you make is therefore made at your own risk. However, once we have received your data, we will use strict procedures and security features designed to prevent any unauthorised or unlawful access to the same and all information you provide to us will be stored securely.

YOUR RIGHTS

You have a number of important legal rights regarding the manner in which personal data relating to you is used. You can find more information about your rights on the Information Commissioner’s Office website – please see https://ico.org.uk/for-the-public.

We have outlined below the key rights which we believe may be relevant to your use of the App.

If you would like to exercise any of these rights then please contact us using the contact information provided below. Please note that you may be asked to provide us with reasonable proof of your identity so that we can be sure that we are discussing or providing your personal data with, or to, you (or if someone is making a request on your behalf, we need to check that they have the authority to do so).

Access to information

You have the right to access certain information we hold about you so that you can be aware of, and verify the lawfulness of, the processing we undertake.

You can exercise your right of access by making what is generally referred to as a subject access request.

We will review each request which we receive and if we agree that we are obliged to provide personal data to you then we will (subject to certain limited exceptions provided under the relevant law) amongst other things: (i) describe it to you; (ii) tell you why we are holding it; (iii) tell you who it could be disclosed to; and (iv) let you have a copy of it (this may include providing an electronic copy). Subject access requests can be made by emailing information.governance@mft.nhs.uk

Right to have information corrected

If you identify that any personal data that we hold about you is wrong, inaccurate or out of date then you may ask us to correct or update it. Please contact us via the details provided below and we will review each request and respond accordingly.

Right to complain

If you are unhappy about the way in which we have processed your personal data then you have a right to raise the issue with the Trust via Patient’s Advice & Liaison Service Tel: +44 (0)161 276 8686 or Email: pals@mft.nhs.uk. In the event that you are not satisfied with the response from the Trust you have the right to lodge a complaint with the Information Commissioner’s Office – as noted above please see https://ico.org.uk/for-the-public/ for further details.

Changes to our privacy notice

We will keep this privacy notice and we may update it from time to time (for example, to reflect changes we might make to our services or to reflect changes in the law or best practice). Any changes we may make to our privacy notice in the future will be posted on this page. We encourage you to visit this page periodically so that you are aware of any changes which have been made. In addition changes may be notified to you by e-mail or when you next start the App. 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.

Contact Details

If you have any comments or concerns regarding our privacy notice, or the manner in which we handle your personal data or if you would like to exercise any of the rights outline above then please do feel free to contact us by one of the following means:

By post: FAO Data Protection Officer, Cobbett House, Oxford Road, Manchester M13 9WL

By email: dpo@mft.nhs.uk

We will consider your comments and respond accordingly. Please note that if you have a ‘support’ query (for example you are having issues in accessing the service) then please contact cfs.me@mft.nhs.uk.