COVID-19

SYMPTOM SCREENING

Privacy Policy

RediCare Limited "RediCare" whose registered office is at 1 Island House, Great Island Enterprise Park, Ballincollig, Co. Cork ("US" "WE" "OUR") is committed to preserving the privacy of all visitors to RediCare.ie and all subdomains therein (referred to as the "SITE"). This privacy policy describes how we use and protect the information that you provide to us.

By using or registering on the SITE, you consent to the collection, use and transfer of your information under the terms of this policy.

Information Collection and Use

Save in the limited circumstances below, RediCare will remain in control of any information collected on the SITE. We will not sell, share, or rent this information to others in ways different from what is disclosed in this statement RediCare may collect information from our users at several different points on our SITE.

Your information will enable us to provide you with access to all parts of the SITE and to supply "The Services" related to the COVID-19 symptoms checking and risk stratification which has been commissioned by your employer or club. I am assuming this privacy policy is limited in scope to the COVID-19 symptoms check service, rather than to broader occ health services which are not relevant for our purposes. It will also enable us to contact you where necessary concerning your COVID-19 symptoms check and referral, if required.

The information about you which we collect consists of:

  • Your basic identity and contact details, which are used to give you access to the SITE and to avail of The Services;
  • Your medical history which you provide to RediCare on the SITE which is used to enable RediCare to carry out a risk stratification which has been commissioned by your employer or club;
  • The responses which you give to the COVID-19 symptom checking questionnaires which you complete on the SITE;
  • Your screening outcomes and/or risk classifications, which are generated based on your responses to the questionnaires.

We will provide access to certain User Information (but not sensitive medical information) to third-party suppliers for them to perform certain functions for us as necessitated by the Member's use of any of the Services — for example, your mobile telephone number and email addresses and the contents SMS messages and emails may be given to mobile network operators for the purposes of providing you messages in connection with the Covd-19 screening services as requested by your employer or club. These suppliers are not authorized to release this information to other third parties.

We appreciate that unsolicited commercial mail is a nuisance, we therefore never disclose your details to any third party for marketing purposes. Unless required to do so by law, we will not otherwise share, sellsell, or distribute any of the information you provide to us without your consent.

Your Personal Health and Biomarkers Data Usage

The following is a summary of how we may share your data to enables us to deliver "The Services"

  • Your data will be used to generate your COVID-19 symptom report which will be sent to you via email after each assessment is completed.
  • Your data may be used to enable a COVID-19 test referral, if needed and where you specifically agree to this.
  • Your COVID-19 risk stratification will be shared with your employer or authorised club official, the two levels of risk stratification are, High and Normal.
    Note: We will never share any of your personal clinical history used to determine your risk stratification with your employer or authorised club official.
  • Your daily COVID-19 symptom screening outcomes will be shared with your employer or club. The employer outcomes will be 'Displaying No Symptoms' or 'Self-Isolate' and the club outcomes will be 'Play' or 'No Play'.
    Note: We will never share any of your personal clinical history with your employer or authorised club official.
  • We may share, if necessary, details of whom you have had close contact with or attendance tracking data for contact tracing purposes, with your employer or authorised club official. Are details of close contacts actually being collected in the survey?
  • Where referral to a COVID-19 test is deemed necessary you will be given the choice to arrange the test with your own Doctor or to use a RediCare Doctor. If you choose to use a RediCare Doctor, your data may be input onto a RediCare's Doctor patient management system for the sole purpose of enabling a referral to the COVID-19 test.
  • Your data is securely stored on the RediCare platform, which is hosted by Amazon AWS in Ireland. I'm assuming there is no export of data outside of Ireland as a consequence of AWS storage?
  • In line with guidelines for the retention of medical data, your clinical history data which informed your risk stratification will be held by RediCare for 8 years from your last contact/engagement with RediCare unless you send us a written request to delete your data prior to this time. This is necessary to provide background data for risk stratification outcomes.
  • Your daily symptom data will be held by RediCare for 3 years from your last contact/engagement with RediCare unless you send us a written request to delete your data prior to this time.
  • Your data may be used for de-identified statistical analysis and reporting on the prevalence of COVID-19, its symptoms and other chronic conditions. Some of this statistical analysis and reporting and analysis may be used for publication purposes in medical, scientific and academic publications. Your data used in this manner will always be anonymous and unidentifiable. Don't think this is relevant to the COVID survey?

The legal basis on which we collect, process, and transfer your personal data as described above is your consent, which you provide by using the SITE and providing your responses to questionnaires on the SITE. For greater clarity, I would recommend that a tick box confirming consent be included at the outset of each questionnaire to enhance compliance with GDPR consent rules.

You can withdraw your consent to our processing of your data at any time by emailing our data protection officer using the contact details described below. This is a suggested process for enabling the withdrawal of consent. There may be a more administratively convenient process for you to prescribe. Please note that, if you withdraw your consent to us processing of your data, we will not be able to share COVID-19 symptom tracking information with your employer or club. This may have the consequence that your employer or club may be unable to comply with their return-to-office or return-to-play obligations with respect to you, meaning that you may be unable to return to work at your office, or to play or train with your club.

AUTOMATED DECISION MAKING

The responses which you give to the COVID-19 screening questionnaires you complete on the Site may result in automated determinations being made about you (for example, whether you are displaying COVID-19 symptoms or not). This automated decision making is based on pre-determined consequences of how you respond to various questions contained within each questionnaire. The outcomes of these automated processes may have consequences for you, as, if you are classified as exhibiting COVID-19 symptoms, you may be required to self-isolate and may not be permitted to return to work at your office or return to play or train with your club.

Use of Cookies

Cookies are small text files that a website transfers to a visitor's hard disk or browser for added functionality or for tracking website usage. In order to measure the effectiveness of our online presence, RediCare may use cookies to determine the path users take on the SITE and to identify repeat visitors of the SITE. We do not use cookies to gather personal information such as a person's name or e-mail address.

Security and Data Protection

RediCare is GDPR compliant and we employ best practice security measures to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction, and damage. Your information will be stored on dedicated server architecture within a secure data centre hosted by Amazon AWS in Ireland.

Data Retention Policy

In line with guidelines for the retention of medical data, your clinical data which informed your risk stratification will be held by RediCare for 8 years from your last contact/engagement with RediCare unless you send us a written request to delete your data prior to this time. This is necessary to provide background data for risk stratification outcomes.

Your daily symptom data will be held by RediCare for 3 years from your last contact/engagement with RediCare unless you send us a written request to delete your data prior to this time.

YOUR RIGHTS

You have the right as an individual to find out what information we hold about you and for what purposes, as well as to make corrections if necessary. You also have the right in some circumstances to object to our continuing to process your personal information, or to ask us to delete, restrict the use of your information. In some circumstances you can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organisations (this is often referred to as the right to 'data portability').

We encourage you to contact us to update or correct your personal information if it changes or if the personal information, we hold about you is inaccurate.

If you are unhappy about how we use your information, we hope that in the first instance you will let us know so that we are able to address your concerns. However, you are also entitled to lodge a complaint with your local data protection authority. The Data Protection Commissioner website is www.dataprotection.ie

If you have questions or concerns regarding our use of your information, or would like to exercise any of your rights, please contact RediCare Limited in the first instance. You may contact RediCare Limited at:

Addressed to: Micheál Ó Cróinín, Data Protection Officer, RediCare Ltd,1 Island House, Great Island Enterprise Park, Ballincollig, Co. Cork, IRELAND |
email: info@redicare.ie.

External Links

The SITE may contain links to other websites. Please take note that RediCare is not responsible for the privacy policies or practices of such other websites. We encourage our users to be aware when they leave the SITE and to read the privacy statements of each website that collects personally identifiable information. This privacy statement applies solely to information collected by the SITE and as part of any health service, we may deliver.

Changes to Privacy Policy

RediCare may, from time to time, make changes to this policy. We recommend that users of the SITE re-visit this privacy policy on occasion to learn of new privacy practices or changes to our policy.

Data Protection Officer

All comments, queries, and requests relating to our use of your information are welcomed and should be

Addressed to: Micheál Ó Cróinín, Data Protection Officer, RediCare Ltd, 1 Island House, Great Island Enterprise Park, Ballincollig, Co. Cork, IRELAND |

email: info@redicare.ie.

Effective Date: 28/08/2020