HEALTHINOTE PRIVACY POLICY
Introduction
This policy (together with our end user licence agreement (“EULA”) applies to your use of our ‘healthinote’ mobile or web app (“healthinote”) on your PC or mobile device (a “Device”). healthinote is not intended for children below the age of 13 and we do not knowingly collect data relating to such children.
healthinote contains links to and from the websites of our partners and other healthcare information providers. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. We advise you to check their policies before you submit any personal data to those websites or use any of their services.
Who is the Data Controller$1
Cognitant Group Limited is the controller and is responsible for your personal data (collectively referred to as “Cognitant”, “we” or “us” in this policy).
Our full contact details are:
Full name of legal entity: Cognitant Group Limited
Email address: dataprotection@cognitant.com
Postal address: Data Protection, Cognitant Group Limited, 41 Cornmarket St, Oxford, Oxfordshire OX1 3HA UK
An exception to the above applies in the case of information provided to us by NHS login. Please note that if you access our service using your NHS login details, the identity verification services are managed by NHS England. NHS England is the controller for any personal information you provided to NHS England to get an NHS login account and verify your identity, and uses that personal information solely for that single purpose. For this personal information, our role is a ‘processor’ only and we must act under the instructions provided by NHS England (as the ‘controller’) when verifying your identity. NHS England’s Privacy Notice and Terms and Conditions are set out here: https://access.login.nhs.uk/terms-and-conditions. This restriction does not apply to the personal information you provide to us separately.
Changes to this policy
We keep our privacy policy under regular review.
This version was last updated on 14 August 2023. It may change and if it does, these changes will be posted on our website and, where appropriate, notified to you by email and/or when you next start healthinote. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of healthinote.
The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you as follows:
Identity Data: name, email address, masked IP address, a random identifier allocated to your Ddevice.
Contact Data: email address and telephone number.
Device Data: includes the type of Device you use, your Device operating system, the type of browser you use, time zone setting and a unique app instance id.
Content View Data: information viewed by you in healthinote or links you select for external sites and content.
Health Data: any information or data about your health or wellbeing which you choose to input into healthinote to store for your use of the platform and to generate reports for you.
Profile Data: includes your content viewing history, preferences, feedback and survey responses.
Usage Data: includes details of your use of healthinote, including frequency, usage patterns etc.
Location Data: includes your approximate location (within 20km) as disclosed by GPS or IP address.
We also collect, use and share “Aggregated Data” such as statistical or demographic data. Aggregated Data could be derived from your personal data but is not classed as personal data since this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific healthinote feature. We may provide such anonymised Aggregated Data to our partners or customers as part of our cooperation or work for them.
Please note that the Content View Data contains information which could be used to make inferences about your health. Together with any specific Health Data that you input into healthinote, these constitute Special Category Personal Data. We do not seek to collect or process any other Special Categories of Personal Data (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, or any genetic and biometric data. Nor do we collect any information about criminal convictions and offences.
How is your personal data collected$2
We will collect and process the following data about you:
Information you give us. This is information (including Identity Data, Contact Data and Health Data) you give us when you register on healthinote, input data into healthinote or in any feedback/correspondence you provide to us (for example, by email or chat).
Information we collect about you and your Device. Each time you use healthinote, we will automatically collect certain data, including Device Data, Content View Data and Usage Data.
Location Data. We may use your Device’s GPS or IP address to determine your approximate current location (within 20 km). Some of our content requires your location for the feature to provide you with the most relevant information (for example from your local health authority). If you wish to use this particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling healthinote’s use of Location Data in your Device settings.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where you have consented for the type of processing.
Where we need to do this in order to provide the healthinote service to you in accordance with our contractual obligations under the EULA.
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.
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
Purposes for which we will use your personal data
| Purpose/activity | Type of data | Lawful basis for processing |
| To activate healthinote and register you as a new user | Identity | Your consent |
| To deliver healthinote services | Identity | Your consent |
| To manage our relationship with you and your use of healthinote | Identity | Your consent |
| To administer and protect our business and the healthinote platform including troubleshooting, data analysis and system testing | Identity | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security) |
| To deliver content to you | Identity | Consent |
| To comply with our legal obligations or to ensure that you or a third party’s vital interests are protected | Identity | Necessary to comply with legal obligations |
Where we have relied on our legitimate interests to process your personal data, you may contact us to obtain more information, including in relation to our assessment of the impact on you.
The law also requires that the use of Special Category Personal Data is subject to satisfaction of an additional condition. In the case of the processing of any specific Health Data that you input into healthinote, we will also rely on explicit consent.
Disclosures of your personal data
We do not disclose your personal data to any third parties except for the operation of the healthinote platform as follows:
Other companies in the Cognitant Group acting as joint controllers or processors and who are based in UK and provide system or service support activities and undertake leadership reporting.
Service providers acting as processors based in the UK and USA who provide IT and system administration services.
Professional advisers acting as processors including lawyers, auditors and insurers based in the UK.
In exceptional circumstances we may have to use your personal data to contact relevant health or other authorities if we considered that your use of the platform gives rise to a risk of serious harm to yourself or anyone else.
If we sell, transfer or merge parts of our business or our assets with a third party then we may disclose your personal data to such third parties in the same way as set out in this privacy policy.
As noted above, we provide certain Aggregated Data reports to our customers and partners in connection with your use of healthinote, however this does not contain any personal data and is fully anonymised.
International transfers
Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Only transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the Information Commissioner; or
Where we use certain reputable service providers, we may use specific contracts approved by the Information Commissioner which give personal data the same sort of protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.
Data security
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password for use of healthinote, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. Except for the operations listed below, your data is kept exclusively within physically secure ISO-27001 compliant data-centres located within the UK or European Union.
In line with many other responsible businesses, we keep back-ups of all our data in our backup service provider’s SOC 2 Type II certified and HIPAA compliant data-centres, hosted in the USA.
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.
Data retention
We only store your personal data while you are still registered as a user of healthinote or as required by law or regulation.
In the event that you do not use healthinote for a period of 12 months, then we reserve the right to treat the account as expired and your personal data may be deleted. This ensures that we only keep personal data to the extent reasonably required to support the healthinote service.
In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for product development, research or statistical purposes, in which case we may use this information indefinitely without further notice to you. We may also use any specific feedback that you provide to us about healthinote in fully anonymised form for marketing and market research purposes.
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.
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. Please note 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.
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.
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 healthinote’s services to you. We will advise you if this is the case at the time you withdraw your consent.
You can exercise any of these rights at any time by contacting us at dataprotection@cognitant.com.
Complaints
Please let us know if you have any complaints regarding our use of your personal data by contacting us at dataprotection@cognitant.com.
You also 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.