SENSELY AND YOUR INFORMATION
Sensely Corporation is based in the United States and includes Sensely UK which is based in the United Kingdom. Sensely UK is registered with the Information Commissioner as a Data Controller and our registration number is ZA194147.
Sensely follows appropriate regional compliance standards including HIPAA in the United States, and General Data Protection Regulations in Europe. Under EU GDPR regulations our Data Protection Officer can be contacted at email@example.com.
If you have any questions or wish to make a request in relation to your information, please contact our Data Protection Officer.
Sensely operates various services which may be accessed through a mobile application or Website (“Sensely App”).
In order to provide you with the Sensely App services that you have signed up to, we must collect, use, store and share information about you, your health and the way that you have used the services.
Where there is a need to transfer information that directly identifies you, we follow the appropriate laws of the location where your data is located, such as HIPAA and EU GDPR. Where there is an occasional requirement of transferring information about you to the United States, we will remove information that directly identifies you.
HOW DOES SENSELY COLLECT MY INFORMATION?
We will collect information about you, either:
- Directly‚ when you enter it into the Sensely App
- Indirectly – when you have entered information into another Sensely App, and they share it through their integrations with the Sensely App, in which case privacy agreements you accept with those parties will apply.
- Automatically‚ when we collect technical information about your use of the Sensely App
The information we collect will be stored electronically. The information includes Personal Data
Basic details about you, such as your name, gender, email address, date of birth, health insurance number, health system reference number
as well as Sensitive Personal Data
Content of your symptom checker questions
Outcome of the symptom checker for example, if you made an appointment
Readings and information from medical devices such as glucose meters, blood pressure monitors, pulse oximeters, pedometers, ECGs and other approved devices which you may use when using the Sensely App.
HOW DOES SENSELY USE MY INFORMATION?
Sensely will use your information for your care in the following ways;
- To deliver the services of the Sensely App
- To communicate with you about your use of the Sensely App, new features and respond to your enquiries
- To request feedback or send surveys to find out if the Sensely App is working well for you and how you used it
- To tailor the content and information that we send or display, and personalized help and instructions to improve your experience of the Sensely App
- To better understand how users’ access and use the Sensely App, both on an aggregated and individual basis, in order to improve the Sensely App and respond to user desires and preferences
- To link the data, you provide to your health insurance Number to allow us to communicate with your health and social care team about your use of the Sensely App
- To undertake systems administration and provide technical support for the Sensely App. This might include accessing your data in order to ensure your requests via the Sensely App are being completed
- To audit the Sensely App, including access to the Sensely App, to ensure the safety and security
- To undertake these activities, your information will be shared internally across our teams. We will work to ensure that only the right people have your information and that they are only given the information they need.
HOW ELSE DOES SENSELY USE MY INFORMATION?
Along with activities related directly to your use of the Sensely App, we also use your information to check that the Sensely App is safe and to provide data for the improvement and planning of services.
This involves using your information to improve Sensely products and quality assurance purposes through:
- Conducting quality assessment and clinical safety reviews, to ensure that the signposting you received was safe and of good quality (for example, was it appropriate that you were directed to self-care?)
- Training and accreditation, certification and licensing activities
WHO DOES SENSELY SHARE MY INFORMATION WITH?
Sensely works hard to ensure that only the right people have your information and that they are only given the information they need.
Your information will be shared internally across our teams such as our technical staff and administrative teams so that we can deliver the services described above
When you are directed to another health care provider, we will share your information with them so that they do not have to ask you questions you have already answered
When we share information with another provider, they assume full responsibility for the lawful and secure processing of your information. You have a right to object to us sharing your information with sharing partners. Our Data Protection Officer will be happy to discuss this with you.
Sensely works with other companies to deliver some of our services including organizations that enable or assist with the:
- Provision of corporate data storage (Amazon Web Services)
- Secure storage of Sensely App data ( Amazon Web Service in the USA and Redcentric in the UK )
- Provision of connectivity and servers
- Undertaking of audits
- Undertaking of research
Personal data will never be made available to organizations not involved in delivering the Sensely App or providing your care without letting you know and giving you a chance to object.
We have contracts in place with these organizations that prevent them from using it in any way other than how we instruct them to. These contracts also require them to maintain good standards of security to ensure your confidentiality.
WILL SENSELY SHARE WITHOUT ASKING ME?
Sometimes we will be required by law to share your information and will not always be able to discuss this with you directly. Examples include:
- Sharing with the police or tax authorities for the detection or prevention of crime
- Where it is in the wider public interest ‚Äì for example, to keep the public safe
- Safeguarding children or vulnerable adults
- When the court has told us we must share
WHAT ARE MY INFORMATION RIGHTS?
Data protection law provides you with a number of rights that Sensely is committed to supporting you with;
RIGHT TO ACCESS
You have the right to obtain:
- Confirmation that your information is being used, stored or shared by Sensely
- A copy of the information held about you. We will respond to your request within one month of receipt or we will tell you when it might take longer.
We are required to validate your identity or the identity of someone making a request on your behalf.
RIGHT TO OBJECT OR WITHDRAWN CONSENT
We collect, use, store and share your information because you have consented for us to do so, but you have a right to object to us doing this, and you may withdraw your consent at any time.
When you make such a request, the data will be anonymized (anything that identifies you will be removed) to ensure it is no longer personal data.
We will then only use the anonymized data for technical, quality and business purposes.
Our Data Protection Officer will be happy to speak with you about any concerns you have.
RIGHT TO CORRECTION
If information about you is incorrect, you are entitled to request that we correct it.
There may be occasions where we are required by law to maintain the original information. Our Data Protection Officer will talk to you about this and you may request that the information is not used during this time.
We will respond to your request within one month of receipt or we will tell you when it might take longer.
When you are making requests for correction or objecting to processing, you have a right to request that we do not further share the information whilst we process your request.
We will let you know once we are no longer restricting the information.
You have a right to request that we send you a copy of the personal data you have provided to us via the Sensely App. You may do this by emailing us to make a request. You can also ask us to send the information directly to another provider if you wish.
You also have the right to make complaints and request investigations into the way your information is used.
DOES SENSELY USE PROFILING OR AUTOMATED DECISION MAKING?
No. Whilst the technology that Sensely uses includes application of certain automatic rules to make decisions about what services might be appropriate for you based on your symptoms, the decision about how to proceed is made by you.
We will undertake profiling in relation to your information. This means we may compile reports that indicate the typical behaviour of particular Sensely App Users. This will be used for the purposes identified under How Does Sensely Use My Information?
You have a right to object to this and to find out the types of reports we are producing.
Our Data Protection Officer will be happy to speak to you about this if you have concerns or objections.
HOW DOES SENSELY PROTECT MY INFORMATION?
Sensely is committed to ensuring the security and confidentiality of your information. There are a number of ways we do this, including:
- Staff receive regular training about protecting and using personal data
- Policies are in place for staff to follow and are regularly reviewed
- We check that only the minimum amount of data is shared or accessed
- We use controlled access to systems to help ensure that the right people are accessing data‚ and are people with a need to know
- We use encrypted emails and storage which would make it difficult for someone to intercept your information
- We report and manage incidents to make sure we learn from them and improve
- We put in place contracts that require providers and suppliers to protect your data as well
- If we send information outside of the regional data compliance area (E.g. HIPAA, EU GDPR), we have approved assurances in place to protect it
Unfortunately, the transmission of information via the internet can never be completely secure. Although we do our best to protect both your personal data and sensitive personal data, we cannot guarantee the security of your data transmitted to the Sensely App any transmission is at your own risk.
HOW LONG DOES SENSELY STORE MY INFORMATION?
Sensely will retain / store your Sensely App Registration information and Symptom Checker information until you withdraw consent.
When you withdraw consent / close your account, the data will be anonymized (anything that identifies you will be removed) to ensure we are not holding information about you that we no longer need.
We will then only use the anonymized data for technical, quality and business purposes.
DOES SENSELY USE MY INFORMATION FOR MARKETING?
Yes, but only with your consent. As listed under How Does Sensely Use My Information? we will use your contact details to email you about new features and updates in relation to your Sensely App usage and request feedback or send surveys to find out if the Sensely App is working well for you.
You can ask not to be contacted in this way by using the unsubscribe link within the notifications and email.
HOW DOES THE SENSELY APP USE MY INFORMATION?
When you register with the Sensely App, your information will be shared with our partner organizations in the following ways:
- Your name, date of birth, gender and postcode will be sent to our secure servers for storage
- Your name, date of birth, gender and postcode will be sent to a spine-matching service who will match your details with your health insurance number and return to our secure servers
- Your health insurance number will be sent securely to provider systems to link with your patient record number
When you speak to the Sensely App, your information will be shared with our partner organizations in the following ways:
- You provide information about how you are feeling and your symptoms
- This information is sent securely to our secure servers for storage
- This information is sent to Sensely and our partner organizations to help us provide the correct signposting to services
- Your symptom checker information will be shared with other navigation services, if you are directed to these
When you make an online appointment through the Sensely App, your information will be shared with our partner organizations in the following ways:
- You provide the Sensely App with consent to share the results of your conversation
- This information is then sent securely to the provider system and an appointment is made