Last updated: 1 July 2020 | Download the PDF version by clicking here.
The purpose of the ImproveWell App is to enable users to submit feedback and suggestions for improvement to your employer or other professional organisation that provided you with an authentication code (“participating organisation”). It is not to be used for reporting incidents or near misses which occur within the workplace. To report an incident or near miss, users must follow the protocols set by the participating organisation.
ImproveWell and your information
How does ImproveWell collect my information?
We will collect information: 1) directly provided by you when you enter it via the App; 2) automatically when you visit the Site or use the App; and 3) received from the participating organisation. The information we collect will be stored on electronic systems.
1. Information directly provided by you
The information includes Personal Data such as your:
- job title;
- place of work;
- e-mail address;
- other contact details;
- other registration information;
- personal description;
- photograph (if you choose); and
- details about how you are feeling about your day at work.
We are collecting, storing and using this information because you have provided your consent. It is not our intention to collect sensitive information about your physical or mental health; please do not provide this information to ImproveWell. If you do provide it, this will be an indication that you consent to us processing this information.
Information collected through the “How I’m Feeling” functionality is presented to participating organisations in aggregate, de-identified form. This functionality is not devised to reveal individual submissions. In some cases (e.g. when participating in small user groups, or a unique combination of user groups, and choosing to share specific information in free text) it is possible for individual submissions to become identifiable.
2. Information collected automatically
We also collect information automatically each time you use the App. This information supports our legitimate interests as a commercial entity, and we have provided justification for these uses below;
ImproveWell does not collect personal data in order to share with third parties (other than our providers as listed) or for commercial gain (beyond the customer relationship and development of our own product) nor do we use your information for any targeted marketing activities.We also want to make it clear that when we are processing the data for these purposes, it is not in identified form. The data is presented in aggregated form and ImproveWell does not link this information to a particular user.
3. Received from the participating organisation
To invite you to the ImproveWell platform, the participating organisation may provide us with Personal Data such as your:
- job title;
- place of work; and
- e-mail address.
How does ImproveWell use my information?
ImproveWell will use your information in the following ways:
- to recognise you as an App user and enable you to make use of the features and benefits of the App, such as recording your improvement ideas, sharing how your day at work is going and completing surveys;
- to provide you with general updates from the participating organisation, for example by notifying you about improvements planned or currently being implemented;
- to inform you about new features and benefits of the App; and
- to respond to any comments or questions you may have and to the feedback you submit via the App.
To undertake these activities, your information will be shared internally across our teams.
How else does ImproveWell use my information?
Along with activities related directly to the participating organisation, we also use your information:
- to improve services provided by the participating organisation;
- to generate statistics, analyse usage and navigation within the App;
- to administer the App; and
- for internal operations, so we can improve the App and present content in the most effective manner for you and your device.
To help organisations measure improvement over time, we may analyse the tone or “sentiment” of free text submissions in aggregated, de-identified form. This helps organisations to identify trends in positive, negative or neutral sentiment. This functionality is not devised to reveal the sentiment of individual data submissions.
Who does ImproveWell share my information with?
ImproveWell works hard to ensure that only the right people have your information and that they are only given the information they need.
- We will disclose some or all of your Personal Data when you download or use the App to allow the participating organisation to review your feedback and implement any necessary follow-up.
- Information collected through the “How I’m Feeling” functionality will be shared with the participating organisation without direct identifiers such as your name and email address.
We will also disclose your Personal Data to the participating organisation and other third parties if:
in the event that we sell or buy any business or assets, in which case we will disclose your Personal Data to the confirmed buyer of such business or assets. We will notify you, giving you an opportunity to object or to withdraw consent.
If we engage third parties to operate the App or provide other specific functions in relation to the App, they will be provided with access to your Personal Data, where necessary, in order to perform their specific functions. Once we have shared information with the participating organisation, they take on full responsibility for the lawful and secure processing of your information. You have a right to object to us sharing your information with the participating organisation and other third parties. Our Data Protection Officer will be happy to discuss this with you. ImproveWell uses other companies to help us deliver some of our services such as:
- Provision of connectivity and cloud-hosted servers (AWS)
- Provision of a 24/7 customer support ticketing system (Zendesk)
- Provision of product analytics to improve customer experience (Amplitude)
- UK-based technology partners involved in business and domestic software development (providers engaged as required)
- Undertaking audits (providers engaged as required)
ImproveWell may use other partners (such as email services or customer-relationship management systems) for low risk Personal Data such as names and email address. These providers can change frequently but always meet the legal standards. If you would like more information on these providers, please let us know.
We have contracts in place with these organisations that prevent them from using your Personal Data in any way other than as expressly authorised by us. These contracts also require them to maintain adequate standards of security to ensure your confidentiality.
Will ImproveWell share without asking me?
Sometimes we will be required by law to share your information and will not always be able to discuss this with you directly. Examples might be:
- Sharing with the police or tax authorities for the detection or prevention of crime
- Where it is in the wider public interest
- to keep the public safe, for example
- To safeguard children or vulnerable adults
- For the purposes of obtaining professional advice (for example, legal advice)
- Because the court has told us we must share
We may sell, share or otherwise transfer information about users of the App in an anonymous or aggregate form with third parties, including advertisers, business partners, and sponsors, for the purposes of, without limitation, understanding customer trends and patterns and managing and improving our commercial and other relationships.
What are my information rights?
Data protection law provides you with a number of rights that ImproveWell is committed to supporting you with. This includes the right to:
- Request access to your information and request a copy of your information
- Object to the way we use your information
- Withdraw Consent
- Request that your information is corrected or updated
- Request that your information is erased
- Request that the way your information is used is restricted
- Make a complaint
- Have your information transferred to a different provider of similar services to ImproveWell
Right to Access
You have the right to obtain:
- confirmation that your information is being used, stored or shared by ImproveWell
- a copy of information held about you
If you only require a particular part of your record, tell us and this can reduce the time it takes to provide it. We will respond to your request within one month of receipt or will tell you when it might take longer. We are required to validate your identity including the identity of someone making a request on your behalf.
Right to Object
We collect, use, store and share your information because you have consented, but you do have a right to object to how we use your information. Our Data Protection Officer will be happy to speak with you about any concerns you have.
Right to Withdraw Consent
You may contact our Data Protection Officer at firstname.lastname@example.org to withdraw consent. If you withdraw consent, we will anonymise the data and use it for reporting activities only.
Right to Correction
If information about you is incorrect, you are entitled to request that we correct it. There may be occasions, where we are required by law to maintain the original information – our Data Protection Officer will talk to you about this and you may request that the information is not used during this time. We will respond to your request within one month of receipt or will tell you when it might take longer.
How does ImproveWell protect my information?
ImproveWell is committed to ensuring the security and confidentiality of your information. There are a number of ways we do this:
- Staff receive regular training about protecting and using personal data
- Policies are in place for staff to follow and are regularly reviewed
- We check that only the minimum amount of data is shared or accessed
- We use controlled access to systems, this helps to ensure that the right people are accessing data
- people with a ‘need to know’
- We use secure emails and storage which would make it difficult for someone to ‘intercept’ your information
- We report and manage incidents to make sure we learn from them and improve
- We put in place contracts that require providers and suppliers to protect your data as well
- We do not send your information outside of the UK
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to the App; any transmission comes with some risk. ImproveWell is located in the UK, and its servers are located in the UK and are subject to data protection laws applicable to the UK. ImproveWell may be offered to users in the United States. Information collected from users in the UK or the United States will be stored and processed by ImproveWell in the UK.
Does ImproveWell collect information from children?
As a platform provided to employers or other professional organisations, no part of ImproveWell’s services are directed at persons under the age of 16. If you are under 16 years of age, then please do not use the App or visit the Site. ImproveWell does not knowingly collect or maintain Personal Data from persons under 13 years of age. If ImproveWell learns that Personal Data of persons less than 13 years of age has been collected without verifiable parental consent, then ImproveWell will take the appropriate steps to delete this information. To make such a request, please contact our Data Protection Officer at email@example.com.
How long does ImproveWell store my information?
ImproveWell will retain / store your App data, in identifiable form until you withdraw consent or the contract we have with the participating organisation ends. When this happens, we will anonymise the data and use it for reporting activities only.
What happens if you make changes to this Policy?
Information for Data Subjects in the EU
In accordance with GDPR, your submission of your personal data to ImproveWell constitutes your consent to allow your personal data to be processed by ImproveWell in the United Kingdom. The UK is not a member of the EU and GDPR does not directly apply. However, the UK has worked to implement GDPR and ImproveWell has ensured that there are measures in place to protect your personal data and reduce the risk for EU data subjects. Please see, How Does ImproveWell Protect My Information.