Mood Diary App for RIO – Privacy Notice

This Privacy Notice aims to give you information on how Totalmobile Limited collects and processes your personal data through your use of its “Mood Diary” application.

It is important that you read this Privacy Notice together with any other privacy notice or fair processing policy 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 other notices and privacy policies and is not intended to override them.

Data Controller and Processor

Totalmobile Limited is the processor of the personal data that you input using the Mood Diary or which we otherwise collect about you. In this Privacy Notice, Totalmobile Limited may be referred to as ”Totalmobile”, “we”, “us” or “our” – but the meaning is the same in each case.

In the majority of cases, the healthcare provider (who referred you to this Mood Diary application) will be the Data Controller but you are advised to contact that healthcare provider should you require confirmation.

Who are We

Totalmobile Limited has been providing IT solutions across many different industries for over 25 years. Our solutions are designed to ensure that data provided by service recipients and end-users is kept secure and only processed for specific purposes.

Totalmobile and Data Protection

As a business, we process a wide array of information (which we refer to below as “data”), both for our own purposes and on behalf of our customers. Totalmobile are committed to safeguarding your information and a big part of this is making sure that you are aware of what information we may hold about you and how we use it.

This Privacy Notice provides guidance on our use of your data, including:

What sort of data we collect about you
Why we process that data
How we process it
Who, if anyone, we disclose your data to
How long we retain that data for
The security measures we have put in place to protect your data
The contact details for our Data Protection Officer
What rights you have over data we may hold on you
How to raise questions and concerns you may have over your data
Your legal rights with regard to the data we hold on you
Our right to make changes to this Privacy Notice from time to time
The Data Collected by the Mood Diary

The Mood Diary application forms part of wider health services provided in conjunction with your NHS Health Care Provider and Servelec Healthcare Limited (which provides administration services on behalf of your Health Care Provider) and has been designed, as part of your agreed treatment plan put into place by your Health Care Provider, to:

allow you to record your mood
record any reasons contributing to your mood
allow you to set reminders to complete your mood log
enable access to your emergency contacts or the safety plan agreed with your Health Care Provider.
Although the Mood Diary allows you to complete these tasks, no data relating to your mood, safety plan, emergency contacts or other health information is made accessible to Totalmobile or stored on their servers.

How We Process Your Data

The Mood Diary application takes the information you provide and transmits it to your Health Care Provider so that it may be added to the medical notes on you held by your Health Care Provider within its computer systems.

The only information Totalmobile will save is your email address, a unique patient ID and an ID assigned to your local Health Care Provider or Trust. This information is stored to allow your mood logs to be matched up with your medical records and to allow you to call up your emergency contacts or safety plan.

Totalmobile will not use your information for any automated decision-making, such as profiling.

Why We Process Your Data

We process your information in this way to allow your Health Care Provider to monitor and assess your wellbeing and to allow you to access your emergency contacts and safety plan should you need it.

If you do not supply this information, the Mood Diary application will not operate as intended and the quality of care you receive may be affected.

The legal basis for this processing for the purposes of the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018 is that set out in Article 9(2)(h) of the GDPR, which is that the processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of an employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law.

Disclosure of Your Data

The data saved by Totalmobile via your use of the Mood Diary application is kept secure and is not disclosed to any third-parties not directly involved in your care.

We will not transfer any data relating to you to any person or organisation outside the European Economic Area.

Security Measures We Have Put In Place To Protect Your Data

We have put in place appropriate security measures to prevent your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your data to those employees, agents, contractors and other third parties who have a need to know. They will only process your data on our instructions and they are subject to a duty of confidentiality.

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

We have taken the following steps to protect your data:

During the onboarding process you will be asked to create a password protected account. This is used to secure communication between the Mood Diary and your patient record.
You’ll then be asked to use the Mood Diary application to scan an image printed on a letter provided to you by your NHS Trust. This image is known as a ‘QR code’. It contains your personal patient identification number and Trust number and will trigger an SMS message to the mobile phone on your personal record. You must enter the pin number you are sent within 10 minutes to progress. This ensures that you, and only you, are accessing and updating your personal record.
Finally you must secure the Mood Diary application itself with either biometric data (thumbprint or facial recognition) or a 6 digit passcode. This gives an additional level of security should your phone be left unlocked whereby the app cannot be accessed without biometrics or the passcode.
Any data, whether retrieved from your patient record, or input by you is stored securely on your device using modern encryption technologies (256-bit AES encryption).
How Long Will We Hold Your Data For?

We will only retain your data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory or reporting requirements. We may retain your data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for data, we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure of your data, the purposes for which we process your data and whether we can achieve those purposes through other means, and any applicable regulatory obligations.

Details of retention periods for different aspects of your data are available by contacting our data protection officer via the details provided below..

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

In some circumstances we will anonymise your 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.

Totalmobile’s Data Protection Officer

Our DPO is responsible for our data protection processes, policies and more general compliance. A key part of this role is to also act as a point of contact for individuals whose data we process and to address any concerns, queries or complaints that you may have.

Our DPO can be reached using the following details:

By post:

Scott Boyle – Information Security and Data Protection Officer

Totalmobile Ltd.

Pilot Point

21 Clarendon Road

Belfast

BT1 3BG

By email:

scott.boyle@totalmobile.co.uk

(Please mark your email ‘For the Attention of the Data Protection Officer’ in the subject line)

By phone:

(+44) 02890 30111

(Please ask Reception to put you through to Scott Boyle)

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your data. These rights include the right to:

Request access to your data.
Request correction of your data.
Request erasure of your data.
Object to processing of your data.
Request the restriction of processing your data.
Request transfer of your data.
Right to withdraw consent to the processing of your data.
If you wish to exercise any of the rights set out above, please contact our DPO (using the contact details above) in the first instance.

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 could 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 could 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.

Your Right To Make A Complaint To The Regulatory Authorities

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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to this Privacy Notice

Totalmobile may update or amend this Privacy Notice from time, for example where data processing activities change, new processing activities are introduced or to reflect changes in legal or regulatory requirements.

Where a material change to this Privacy Notice is made, this will be highlighted and communicated where appropriate. We would encourage you to periodically review this Mood Diary Privacy Notice to ensure that you are aware of the latest information available.

Our more general Privacy Notice and Notification is also available on our website at the following link: https://www.totalmobile.co.uk/privacy-notification/