1. Introduction
The Healthy Habits App is intended to be used by research participants as part of the Design & Feasibility Phase of the Healthy Ageing study (SETREC Reference number: 6875521). The study is sponsored and managed by Imperial College London. All study participants are required to provide informed consent according to the study’s research protocol.
2. Data Collected during participation
Whilst being involved in the Design & Feasibility Phase and using the Healthy Habits app, we may collect, store, and process the following information about you. Data will be process and stored in accordance with Imperial College Privacy Policy.
Personal Information – The Healthy Habits app collects information including your first name, year of birth, sex at birth, height, and number of people you live with for the purpose of the sutdy. This information is inputted by yourself or with support from a research assistant.
Health and fitness data – Information such as your step count, activity level (in calories, heart rate, body composition and sleep quality will be collected by the Withings health devices and sent to the app as you use it. Information such as environmental temperature, humidity, motiona events and door opening will be collected by Sonoff devices. Participants are provided detailed information about these sensors and are required to consent to their use in the study protocol at recruitment before using the app. The app will also collect information about your grip strength and self-reported sleep quality, wellness and healthcare utilisation, which you will input into the app during your use of the app. The app will also record measures of your independence, mood and wellbeing collected through a number of validated health questionnaires which you will complete during your use of the app.
Cookies - Our technology uses cookies to distinguish you from other Healthy Habits users for the purpose of the clinical trial. For more information on the cookies we use and the purposes for which we use them see the ‘Cookies and Tracking Technologies’ section below. Cookie data collected is based on your consent to participate in the Design & Feasibility Phase.
Technical information - Technical information collected by the OnTrack App includes information about your app usage (time and frequency you perform certain actions or ‘events’), and other information (server processing times).
Location information - We may collect location information for any device provided by the Healthy Ageing Study in case they are reported as lost or stolen exclusively.
3. Legal Basis
All study participants enrolled in the Healthy Ageing Study provide informed consent, this is the basis for processing the data.
Imperial College London uses personally-identifiable information to conduct research to improve health, care and services. As a publicly-funded organisation, we have to ensure that it is in the public interest when we use personally-identifiable information from people who have agreed to take part in research. This means that when you agree to take part in a research study, we will use your data in the ways needed to conduct and analyse the research study. Our legal basis for using your information under the General Data Protection Regulation (GDPR) and the Data Protection Act 2018, is as follows:
Imperial College London - “performance of a task carried out in the public interest”; Health and care research should serve the public interest, which means that we have to demonstrate that our research serves the interests of society as a whole. We do this by following the UK Policy Framework for Health and Social Care Research.
Where special category personal information is involved (most commonly health data, biometric data and genetic data, racial and ethnic data etc.), Imperial College London relies on “scientific or historical research purposes or statistical purposes.
4. User Consent
As part of the Design & Feasibility Phase, we ask for your agreement to process certain data for specific purposes. You have the right to withdraw your consent at any time and without your rights being affected. For more information on the withdrawal process please contact the Design & Feasibility Phase manager using the contact details provided in the relevant section below.
5. Data Retention
Data collected for the purposes of the Design & Feasibility Phase will be retained by Imperial College London for a minimum of 10 years after the conclusion of the study, this may include anonymised and non-anonymised data.
6. Data Security
Data collected via the Healthy Habits App is stored in secure access-controlled computer databases that can only be accessed by specific members of the research team.
We use Amazon Web Services (AWS, Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855, Luxembourg) to host data on the Healthy Habits App. Your data is processed on servers in the EU. For further information, please refer to AWS’s privacy policy here: https://aws.amazon.com/privacy/. The processing of your data in AWS servers is based on your consent to participate in the Design & Feasibility Phase.
At the end of the study, data collected through the devices will be kept pseudonymous so that it cannot be linked back to you without a key, stored separately under encryption. Study data may be shared with other researchers for the purpose of future research studies.
The Chief Investigator of the Healthy Ageing Study is responsible for preserving the confidentiality of participants taking part in the study. Information regarding the participants will be kept confidential and managed in accordance with the General Data Protection Regulation, The Research Governance Framework for Health and Social Care, and Research Ethics Approval.
7. User Rights
Under data protection legislation (GDPR), you have the following rights with regards to your personal information:
8. Cookies and Tracking Technologies
We use a third party service (Amplitude, Inc. 201 Third Street, Suite 200, San Francisco, CA 94103) that uses cookies to distinguish you from other users of our services for the purpose of the clinical trial. Amplitude is not able to collect any of your personal information. More information on Amplitude’s privacy policy can be found here: https://amplitude.com/privacy
Additionally, we use Sentry (Functional Software, Inc, 45 Fremont Street, 8th Floor, San Francisco, CA 94105) to identify, monitor, and alert our developers to errors, bugs, and other performance issues that may be occurring in the Healthy Habits App. Sentry is not able to collect any of your personal information. More information on Sentry’s privacy policy can be found here: https://sentry.io/privacy/
9. Changes to the Policy
We may update this policy from time to time in response to changing legal, regulatory, or technical developments. When we update this policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material changes to this policy if, and where, required by applicable data protection laws.
You can see when this policy was last updated by checking the date displayed at the top of this policy.
10. Contact Information
For questions regarding the software applications please contact the Healthy Ageing Team via email at [email protected]
If you need more information about how we handle your data or wish to make a complaint, please contact the research team first at:
Email: [email protected]
Phone: 020 7594 6950
Following our response, if you are not satisfied please contact Imperial College London’s Data Protection Officer via email at [email protected], via telephone on 020 7594 3502 and/or via post at Imperial College London, Data Protection Officer, Faculty Building Level 4, London SW7 2AZ.
If you remain unsatisfied with our response or believe we are processing your personal data in a way that is not lawful you can complain to the Information Commissioner’s Office (ICO) via www.ico.org.uk. Please note the ICO does recommend that you seek to resolve matters with the data controller (Imperial College London) first before involving them.
Healthy Habits