PillPacCare Privacy

1. Purpose of this Privacy Notice

This privacy notice aims to give you information on how PillPacCare collects and processes your personal data as a user of the PillPacCare web and mobile based app e.g. as a care provider or care worker. This includes any data you may provide through our web portal, or via the app. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

2. Third Party Links

When you use our app, there may be links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

3. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

 

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender
  • Contact Data includes email address and telephone numbers
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this app
  • Profile Data includes your username and password.
  • Usage Data includes information about how you use our web and mobile based app, products and services
  • Communications Data includes text messages/push notifications with information relating to staff news and training relevant to you

    •  

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific app feature, or the number of incidents recorded, or patients visited. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

 

4. Whether information has to be provided by you, and if so why

We require that you provide us with certain information so that you can use this app. We must, for example, collect certain identity details so that we can verify your identity when you log in, and therefore safeguard the security of patient and service user information. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.

5. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions – you may give us your Identity, and Contact information when you use this app.
  • Automated technologies or interactions -
    • As you interact with our website and mobile 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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details].
  • Third parties or publicly available sources - We may receive personal data about you from various third parties and public sources as set out below:
    1. - Identity and Contact Details supplied by your employer, agency or Trust.
    2. - Technical Data from analytics providers such as Google based outside the EU.
6. How we use your personal data
# Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
1 To register you as a user of the app
  • Identity
  • Contact
  • Profile Data
    		•  Necessary for our legitimate interests
    2 To manage our relationship with you which will include notifying you about changes to our terms or privacy policy
  • Identity
  • Contact
  • Profile
    		•
  • Necessary to comply with a legal obligation
  • Necessary for our legitimate interests (to keep our records updated and to study the use of our services)
    		•
    3 To administer and protect our business and website/ mobile based app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  • Identity
  • Contact
  • Technical
    		•
  • Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation).
  • Necessary to comply with a legal obligation
    		•
    4 To provide you with relevant communications and notifications
  • Identity
  • Contact
  • Profile
  • Usage
  • Technical
    		•
  • Necessary for our legitimate interests (to improve the service we can provide to you and provide you with relevant information).
  • Necessary to comply with a contract
    		•
    5 To use data analytics to improve our website/app, products/services, marketing, customer relationships and experiences
  • Technical
  • Usage
    		•
  • Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website/app updated and relevant, to develop our business and to inform our marketing strategy).
    		•
    6 To protect and safeguard the patient/ service user data which may be accessed via the app.
  • Identity
  • Contact
  • Profile
  • Usage
  • Technical
    		•
  • Necessary for our legitimate interests, and those of patients/service users.
  • Necessary to comply with a legal obligation.
    • 7 To provide employers, agencies and Trusts with information about information about the location of Care Providers, and visit time.
  • Identity
  • Contact
  • Usage
  • Technical
    		•
  • Necessary for our legitimate interests and those of employers, agencies and Trusts.
    		•
    8 To maintain accurate records of treatment and care provided to patients and service users, which includes recording who carried out the relevant treatment or care task or administered a medication. This is important in order to protect the safety of patients and service users
  • Identity
  • Contact
  • Usage
  • Technical
    		•
  • Necessary to comply with a legal obligation
  • Necessary in the legitimate interests of Care Providers, Patients and Service Users.
    		•
    7. Cookies

    You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website/ mobile app may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

    8. Change of Purpose

    We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

    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.

    Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules.

    We may have to share your personal data with the parties set out below for the purposes set out in the table above.

    • External Third Parties as set out in the Glossary
    • Specific third parties as set out in the Glossary
    • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice

    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

    9. International Transfers

    We will only process your data within the UK or within the EEA (European Economic Area).

     

    10. Data Security
    How long will you use my data for?

    We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Most information collected on the App is routinely destroyed after five years by PillPacCare.

    We are required to retain information collected via this app which forms a part of health and care records, in compliance with the law and guidance which may be issued by the Department of Health and other authorities.

    In some circumstances you can ask us to delete your data: see “Request erasure” below for further information.

    In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

    11. Your Legal Rights

    Under certain circumstances, you have rights under data protection laws in relation to your personal data.

    • Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
    • Request correctionof the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
    • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
    • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
    • Request the restriction of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
    • Request the transfer of your personal information to another party.
    • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

    No fee usually required

    You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

    What we may need from you

    We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

    Time limit to respond

    We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

     

    12. Glossary
    Lawful Basis

    Legitimate Interest means the interest of our business in conducting and managing our business to enable us to provide the best service and the best and most secure experience for users. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities, by contacting us.

    Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

    Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

     

    Third Parties

    Specific Third Parties

    Personal information collected via the mobile app and website is accessible to the agency, trust or company who has entered into a contract with PillPacCare, and their authorised employees.

    Occasionally, we may receive a request from a patient or service user for a copy of their records. If we receive such a request, we will forward it to the relevant Trust, Agency or company who has contracted PillPacCare. Some of your information may need to be disclosed as a result of such a request, such as where your name forms a part of an individual’s care records.

    We will not share your personal information with any other third party unless required to by law.

     

    How to complain:

    We hope that we can resolve any query or concern you raise about our use of your information.

    The General Data Protection Regulation also gives you the right to lodge a complaint with the Information Commissioner (ICO) who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

     

    Changes to this privacy notice

    This privacy notice was published on 17/09/2018 and last updated on 07/03/2019.

    We may change this privacy notice from time to time, when we do we will inform you of this.

     

    How to contact us

    Please get in contact if you have any questions about this privacy notice or the information we hold about you.

     

    Our full details are:

    PillPacPlus
    Unit 30, 62 Fenaghy Road,
    Ballymena,
    Co. Antrim,
    BT41 1FL
    info@pillpaccare.com
    +44 (0) 28 2565 7856