Safe2Go Privacy Policy

PART A: THE POLICY, which includes:

  1. Important information and who we are
  2. Important information and who we are
  3. How is your personal data collected
  4. How we use your personal data
  5. Disclosures of your personal data
  6. International transfers
  7. Data security
  8. Data retention
  9. Your legal rights

PART B: GLOSSARY

PART C: DESCRIPTION OF CATEGORIES OF PERSONAL DATA

PART A: THE POLICY, which includes:

1. Important information and who we are

Hamill Digital Healthcare Solutions Limited is the controller and is responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this policy).

We are the Data Controller (as defined in the Data Protection Act 2018) of the personal data you pass us.

If you have any questions about this privacy policy, please contact us using the details set out below.

Contact details

Our full details are:

  • Full name of legal entity: Hamill Digital Healthcare Solutions Limited
  • Name or title of: Louise Hamill
  • Email address: dataprotection@safe2go.live
  • Postal address: Turnberry House Suite 2:4, 175 West George Street, Glasgow G2 2LB

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues or other competent supervisory authority of an EU member state if the App is downloaded outside the UK.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Services

We will hold your personal data and pass it to a NHS tracing service, which will include any agency or body providing a tracing service, upon their request. This could include your contact details, what venue you were at and how long you were there.

We will be paid by the venue you attend for this service. They will not handle your data.

This is to allow tracing for COVID-19 and any other disease, virus or condition which is the subject of national tracing.

We may transfer or disclose all or any part of your personal data. This is information you pass to us by inputting details onto our website (our “Site”). You will access that Site by scanning a QR code.

2. The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

  • Identity Data.
  • Contact Data.
  • Device Data.
  • Location Data

We explain these categories of data below.

3. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. However, some of this information may be disclosed by implication based on the locations you attend; for example, your religion may be inferred if you give details about attending a place of worship.

4. How is your personal data collected?

We will collect and process the following data about you:

  • Information you give us. This is information (including identity, contact, location and communications data) you consent to giving us about you by filling in forms on our SIte, or by corresponding with us (for example, by email or chat). It includes information you provide when you register with or use the Site, or scan a QR code. If you contact us, we will keep a record of that correspondence.
  • Information we collect about you and your device. Each time you visit our Sites we may collect data about the device you use to do so.
  • Location Data. The QR code you scan will be dedicated to the location in which you scan it. We will keep track of what location you are in and over what times.
5. How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

  • Where you have consented to the use.
  • Where a track and trace team request that we share your personal data with them for operating. This will be to allow them to contact you. They will be given the personal data we hold about you. You consent to this when you fill out personal data on the Site.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation. More details about the lawful bases of processing are set out in Part B below.

Purposes for which we will use your personal data

Purpose/activity Type of data Lawful basis for processing
To notify the NHS or a track and trace body of your details should they request that of us or a venue you have visited Identity
Contact
Location 		Your consent Legitimate interest Public interest
To manage our relationship with you Identity
Contact 		Your consent Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To administer and protect our business including troubleshooting, data analysis and system testing Identity
Location
Contact
Device 		Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To monitor your attendance at participating sites Identity
Contact
Device
Location 		Your Consent
Legitimate interest
Public interest.
6. Disclosures of your personal data

We will disclose your personal data to the NHS or a track and trace agency, who will use it for track and trace purposes. We understand that they will be the controller of that data jointly with us and that their processing of it will be considered in the public interest.

We will disclose your personal data without seeking further consent from you to:

  • the NHS track and trace team, or a similar agency, if so requested by them or a venue you have attended; and
  • 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 policy.
7. International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

8. Data security

All information you provide to us is stored on our secure servers. It is encrypted and rest and in transit using 256 bit encryption.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

9. Data retention

We will retain your personal data for a maximum of 29 calendar days from the date that you share it with us, or (if longer) one day more than any track and trace notification period that applies to a venue you have attended.

Our objective is to erase your personal data one day after the track and trace notification period that applied to a venue that you have attended.

In some circumstances we will 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.

10. Your legal rights

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

These rights are further explained at 1.3 in Part B of this policy.

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer or your personal data.
  • Right to withdraw consent.

You can exercise any of these rights at any time by contacting us.

PART B: GLOSSARY

1.1 Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. 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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Public interest refers to the basis of processing as set out in section 8 of the Data Protection Act 2018.

1.2 Third parties

The National Health Service in England, NHS Scotland, NHS Wales, and Health and Social Care in Northern Ireland (NHS) who are operating a track and trace system for tracking coronavirus patients and those with whom they have come into contact and any agency engaged to provide such services.

1.3 Your legal rights

You have the right to:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. For example, as part of our participation in the NHS track and trace scheme, we are expected to hold personal data for 21 calendar days after you visit a participating site, therefore, we will have a good reason for continuing to process your personal data within this period and may be unable to comply with your request.
  • Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. For example, as part of our participation in the NHS track and trace scheme, the NHS may request that we process your data as part of this scheme.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • if you want us to establish the data's accuracy;
    • where our use of the data is unlawful but you do not want us to erase it;
    • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • 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. Even if you withdraw your consent, we may continue to process your personal data using a different lawful basis as set out in this policy.

PART C: DESCRIPTION OF CATEGORIES OF PERSONAL DATA

  • Identity Data: first name, last name, title, date of birth, gender.
  • Contact Data: residential address, email address and telephone numbers.
  • Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.
  • Location Data: includes the location of participating sites that you have visited and how long you were there.