HeadSmart - Privacy Policy

Collaborations

Co-investigators

Who are we?

This study is being conducted by the King’s Centre of Military Health Research based at King’s College London in collaboration NIHR Health Protection Research Unit (HPRU): Emergency Preparedness and Response. Our research is conducted within the King’s College London governance framework which ensures that our work is carried out to high scientific and ethical standards.

King’s College London (KCL) is the sponsor for this study based in the UK. We will be using information you provide through the HeadSmart app and Qualtrics in order to undertake this study, and we will act a data controller for this study. This means that King’s College London are responsible for looking after your information and using it properly.

The KCL Core Privacy Notice information can be found here: https://www.kcl.ac.uk/terms/privacy. This privacy notice is in addition to the KCL one and explains how we use data that you share with us.

Study background

This study was setup in 2020 by the King’s Centre for Military Health Research, based within King’s College London, to investigate changes in young adults’ wellbeing, behaviours and attitudes during and after lockdown. We are currently in an unprecedented situation and this study will inform the research community on the impact of coronavirus.

What information are we collecting?

We are in collecting information related to your experiences of coronavirus, your mental health and physical activity in addition to a small amount of demographic data. We will use this information to evaluate how coronavirus is impacting young adults, and to inform future research.

Do we share your information with other organisations?

We use third parties (Qualtrics and Google Firebase) to process some of your personal data on our behalf. When we allow them access to your data, we do not permit them to use it for their own purposes. We will not share your personal information with any external organisations. On rare occasions, we may be required or permitted to share personal information by law. For example, if we find concerns through the data, we collect using HeadSmart, then we will inform the NHS and Public Health England so that support can be put in place.

We will publish the anonymised findings in scientific papers and we will publicise them in the public health and policy communities, e.g. by making them available for relevant newsletters and websites. Scientific papers will contain only anonymous, aggregated data (e.g. percentages and averages) presented as tables and figures. The scientific papers will not contain any data on individual participants.

How long will we hold the data?

King’s College London will keep identifiable information about you for 4 years after the study has finished, to enable us to manage the data. If, in 4 years no future analyses are planned, all the data we hold will be securely destroyed.

How do we keep your information safe and secure?

Any information that could identify you is held securely with strict arrangements about who can access the information. At King’s Centre for Military Health Research, all paper-based documents will be held in a locked filing cabinet in an alarmed office, and a secure off-site archive. All electronic information will be held securely on encrypted servers. Access to all information will be strictly limited to authorised members of the King’s Centre for Military Health Research study team. The data file used for analyses by the study team will be de-identified, meaning we remove all names, and other identifiable information. This information will be stored separately from the analyses file, and password protected and encrypted.

The information will only be used for the purpose of health and care research. It will not be used to make decisions about future services available to you, such as insurance.

What is the legal basis for holding these data?

The lawful basis for processing this information is:

Article 6(1.e) of the General Data Protection Regulation (GDPR): processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

The special condition category is article 9(2)(j) of the General Data Protection Regulation (GDPR): processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) based on Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

How can you access your own data?

You can contact Dr Daniel Leightley ([email protected]) for further information.

Rights of access

You have the right to see the information we hold about you. If you would like to access your information please contact the KCL Data Protection Officer: Mr Albert Chan (Assistant Director of Business Assurance) Information Compliance team:

King's College London, Waterloo Campus Room 5.20, James Clerk Maxwell Building, 57 Waterloo Road, London, SE1 8WA; or by email: [email protected]

How can I object to my data being used?

Article 21 of the GDPR gives individuals the right to object to the processing of their personal data.

If you wish to object to your personal data being processed please email your reason(s) to the KCL Data Protection Officer: Mr Albert Chan (Assistant Director of Business Assurance) Information Compliance team, King's College London, Waterloo Campus Room 5.20, James Clerk Maxwell Building, 57 Waterloo Road, London, SE1 8WA; or by email: [email protected] Objections will be responded to without undue delay and within one month of receipt.

Complaints

If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter. If you are not satisfied 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).

Our Data Protection Officer is Mr Albert Chan and you can contact them at Information Compliance team, King's College London, Waterloo Campus Room 5.20, James Clerk Maxwell Building, 57 Waterloo Road, London, SE1 8WA; or email: [email protected]

Information for researchers

We will not make any identifiable data publicly accessible because we need to protect the confidentiality and security of the individual cohort members. However, participants who consent to have their data shared for research purposes we will make the data available upon completion of the study. Please contact Dr Daniel Leightley ([email protected]) for more information.

General enquiries

For general enquiries relating to the study, or to find out more about how we use your information please contact Dr Daniel Leightley ([email protected]) for more information.

Our Privacy Notices are regularly reviewed and updated.

Last reviewed: 04/05/2020; Last updated: 04/05/2020; Updated by: Dr Daniel Leightley