INTUI RESEARCH App
Effective: October 27th 2020
Flinders University (ABN 65 542 596 200) established under The Flinders University of South Australia Act 1966 (SA) is the developer and operator of:
- the INTUI RESEARCH Platform website (“the Site”);
- the Android and iOS INTUI RESEARCH App (“the App”); and
- the INTUI RESEARCH Admin dashboard (“the Dashboard”).
Flinders University is responsible for hosting and maintaining the Site, the App and the Dashboard (collectively “the Services”) on behalf of the affiliated research organisation undertaking and administering the research study that you have enrolled in.
Flinders University and the affiliated research organisation may also be referred to as “we”, “our” or “us”.
We realise that your personal information is sensitive, and we understand that you trust us to be very careful with your information. We are committed to protecting your personal information through abiding by the Australian Privacy Principles within the Privacy Act 1988 (Cth).
This policy covers the following areas:
- Your personal information: what we collect and hold and why we collect and hold it;
- Disclosure to third parties: why we might disclose your personal information and who we might disclose it to;
- Access, corrections and complaints: how you might access and correct if necessary the personal information we hold about you, and how complaints about any breach by us of the Australian Privacy Principles might be made and dealt with; and
- Our security measures.
If you have any questions or concerns about our policy, you can email us: firstname.lastname@example.org
1. What information about me is collected?
We collect both personally identifiable information and non-personal sensitive information about you. “Personally identifiable information” is information which can identify you and includes information you provide when you register with the Services such as your name, age, gender and contact details (e.g. email address). We also collect “sensitive information”, including any health information you provide to the App.
You may choose not to provide “sensitive information”, but this may mean that some of the features of the Services will not be available.
We will never use your data for commercial purposes.
From time to time we may ask you for feedback about our Services. This information allows us to better understand the needs of our users and to gather information about health issues and trends. We store answers but these are not linked to identifying information about you and they will not be shared with third parties.
Personally Identifiable Information
“Personally identifiable information” is information which can identify you and includes information you provide when you register with the Services such as your name, age, gender and contact details (e.g. email address). It also includes any information that may be used to reasonably identify you, such as your location data (GPS coordinates at any given moment).
If we do not collect your personal information we are unable to:
- Connect you to your affiliated research organisation and share with them your health data; and
- Provide you with personalised health monitoring and relevant health content.
Sensitive information on your health that you provide within the App that is linked to your personal identifiable information will only ever be accessed by your affiliated research organisation – based on the Study Code applied during the registration process.
We will never share your identifiable details or your personal level location and movement data with anyone.
For your protection, we consider any health information and associated data collected by our Services to be “sensitive information”. This is information about you, your health and your symptoms, as well as data shared by your phone such as your IP address and location.
We process this sensitive data to:
- provide you with personalised health monitoring and content;
- better understand the progress and trajectory of health problems; and
- advance scientific research into the links between a patient’s health and their engagement with treatments and strategies in line with the study objectives.
After you install the app, we may continuously collect your location and movement data from your phone (e.g.: every few minutes) and ask you to complete regular health check-ins.
We store this sensitive data on a secure cloud database hosted in Australia separately from the personally identifiable information that can be used to identify you.
Algorithms running on the cloud assess your responses to provide you with personalised insights and content.
Your personal level location and movement data is encrypted in a non-human readable format before it is transmitted from your device. We only use your personal level location data to determine metrics, such as: how many places you have visited, what types of places you are visiting and how often you are visiting them. We never share your personal level location details to reveal or monitor where you have been.
We send you notifications that include tips and strategies along with reminders to complete your regular check-ins. The information we provide through our Services is not intended to be, and should not be treated as, providing professional or medical advice.
Further to this, we may share your sensitive data with the following Health Authorities:
- Flinders University;
- Government health organisations (including SA Health); and
- the affiliated research organisation administering the research study you have enrolled in.
Prior to sharing your sensitive data with Health Authorities for the purposes of research, we de-identify and anonymise the data.
These parties will use this data to conduct their nominated research study and guide health officials to improve health services and outcomes.
We will delete and destroy all sensitive data collected through the App when it is no longer relevant to monitoring your health nor required for the purposes of the research study.
When you use our Services, we may collect log information. This information may include your page access request, Internet Protocol (IP) address or Device ID, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser. Log information helps us to gather information about how our Services are being used such as the pages visitors are viewing or features users are accessing.
2. Will any information be used or disclosed?
Other than as referred to below, we will not use or disclose any personal information about you without your consent unless all identifying information about you has first been removed. There may be exceptional circumstances where this may not be possible, such as if disclosure is required by law, is necessary to protect our rights or property or any member of the public, or to lessen a serious threat to a person’s health or safety.
If you do not wish for your information to be disclosed or used as referred to below, please deregister from the Services and contact us as soon as possible at email@example.com to let us know.
Sensitive information on your health that you provide within the App will only ever be accessed by the affiliated research organisation administering the research study you have enrolled in – based on the Study Code applied during the registration process. Further to this, sensitive information may be de-identified and forwarded to Flinders University, Government health organisations (including SA Health), and the affiliated research organisation administering the research study you have enrolled in (collectively “the Health Authorities”) for the purposes of ongoing research. The Health Authorities utilise this information to conduct their nominated research study and guide health officials to improve health services and outcomes.
We may disclose aggregate health and sensitive information from the Services to health researchers including for the purpose of identifying health patterns that could support health care practitioners recommending health interventions at an earlier stage. We never disclose your personal identity details with this information unless there exists independent approval by a National Health and Medical Research Council (NHMRC) ethics committee for the affiliated research organisation administering the research study to receive and handle such data.
We may use your sensitive information on a de-identified basis for analysis, research and quality assurance and improvement purposes. If you consent to take part in future research, we may provide your personal (contact) information to researchers who may wish to contact you regarding relevant research approved by an independent ethics committee.
We may also disclose your sensitive information to third party service providers (such as our IT service providers) to the extent necessary to provide services to us.
We use your personal information to verify your identity, notify you of new or changed services, tailor the content you see within the Services and to contact you as required.
Email communication that you send to us via links in our Services may be shared with others working with us in relation to the Services.
Third party links
Transfer of personal information overseas
We do not transfer personal information from the Services to persons outside Australia.
3. What if I want to access or correct my personal information or lodge a complaint?
If you wish access or correct your personal information, or complain about how we have handled your personal information, please contact our Privacy Officer:
Telephone: (08) 8201 5172; or Email: firstname.lastname@example.org; or Post: The Privacy Officer, INTUI RESEARCH App Integrity, Governance and Risk Division GPO Box 2100 Adelaide, 5001
We will endeavor to:
- provide an initial response to your query or complaint within 5 business days; and
- resolve your query or complaint within 21 business days.
If you are still not satisfied, you can contact the Australian Privacy Commissioner (see http://www.oaic.gov.au/about/contact.html or call 1300 363 992).
4. How can I cancel my registration?
5. How do you keep my information safe?
We are dedicated to protecting the security of your information and take all reasonable precautions to protect it from unauthorised access, modification or disclosure. Your electronic information is stored in secure Australian data centres. However, as we cannot guarantee the security of communications over the Internet, we cannot give an absolute assurance that your information will be secure at all times. Whilst we take every precaution to secure your data during transmission and when stored, transmission of personal information over the Internet is at your own risk, and we will not be held responsible for events arising from unauthorised access to your personal information.
6. Future Changes