ANATOMAP LIMITED



 INJURY CAPTURE APPLICATION PRIVACY POLICY

The Injury Capture (“IC”) App is used to accurately record injuries suffered by a victim of crime and shared with the police and in some cases a medical professional as a result of violent crime. It also is used by witnesses and relatives of the victim to provide additional supporting information. 

Importantly, any personal details you provide may be shared with the victim, any witnesses or medical professionals when you use the App. We will remind you of this before you submit any personal data using the App. 

1. INTRODUCTION

At Anatomap Limited (referred to as “we”, “us”, “our”) we take privacy seriously and we are committed to protecting it. 

This policy relates to our IC mobile application software (“App”) and it explains when and why we collect personal information about you, how this information is used, the conditions under which it will be disclosed to others and how it is kept secure. 

Anatomap Limited (a company registered in England and Wales with company number 12262876) is the data controller in relation to the processing activities described below. This means that we decide why and how your personal information is processed.

This policy, together with the App End User Licence and our Cookie Policy and any additional terms of use incorporated by reference into the End User Licence or our Cookie Policy (our “Terms of Use”) applies to your installation of the App onto a mobile telephone or other device (“Device”) and your use of its services. 

By consenting to the installation of the App onto a Device, creating your user account, providing your consent to the installation and by then using its services (inclusive of uploading any content via the App to our Microsoft Azure servers) you are deemed to have understood and accepted our Terms of Use. You have also understood the legal basis on which we are processing of your personal data (inclusive of (but not limited to) your name and role). 

You may subsequently withdraw your consent at any time by contacting us with the details provided at the end of this privacy policy, but that will not affect the lawfulness of any processing carried out before your withdrawal of consent. You may also withdraw your consent by deleting the IC App. 

Our Terms of Use may change from time to time and we will notify you of any changes when you access the App. Please review any changes we make from time to time to ensure that you’re happy with your continued use of the App.

2. PERSONAL INFORMATION WE COLLECT 

When you download or use the App, the categories of information that we may collect about you are as follows: 

• personal information that you voluntarily give to us by entering information into or via the App (including when registering to use the App) and uploading content via the App or otherwise and may include: 

• name;
• title;
• email address;
• police number;
• police station;
• contact telephone numbers; and
• information contained in our correspondence or other communications with you,

• information that we ask you to provide when you report a problem with the App. If you complete any surveys that we ask you complete for research purposes, we will collect information in such circumstances as well, including your name, address, email address, phone number and enquiry details, which may include records of any correspondence and responses to any surveys; and

• information that we collect about you and your Device, which we may do automatically. This includes (but is not limited to) weblogs, communication data, and the resources that you access. We may also automatically collect technical information, including anonymous data collected by the hosting server for statistical purposes, the Internet protocol (IP) address used to connect your computer/Device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, your Device IMEI and other technical information about your Device. We may also collect any personal information which you allow to be shared that is part of your public profile, time zone setting, browser plug-in types and versions, operating system and platform.

3. HOW WE USE YOUR PERSONAL INFORMATION

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data and to the extent that we are legally able to in the following circumstances: 

• where you have consented before the processing, such as the consent you provided when you downloaded the App;
• where it is necessary for us to provide the services of the App to you; 
• where it is necessary for our legitimate interests (or those of a third party); and
• where we need use it to comply with a legal or regulatory obligation (e.g. to assist any public authority or criminal investigation body, to identify you when you contact us or to verify the accuracy of data we hold about you).

We may use and process your personal information where it is necessary for us to provide the services of the App to you and pursue our legitimate interests, or that of a third party for the following purposes:

• to provide your details (name and photograph) to support the collection of evidence from a victim of violent crime and/or domestic violence; 
• to share information and your personal data (name and photograph) with victims, witnesses and medical professionals (where applicable);
• to correspond or communicate with you;
• to verify the accuracy of data that we hold about you;
• for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
• for the management of queries, complaints or claims; and
• for the establishment and defence of our legal rights.

We may also anonymise your personal data so that it may not be linked back to you and we may use this data for research, analytical and development purposes to improve the App.

4. OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION

When you consent to providing us with your personal data, you also consent to us sharing your personal data with the third parties set out below:-

• the victims and witnesses will have access to your name and photograph (if uploaded) as part of the App service. 
• medical professionals who may be involved in a review of the victims health and injury information. 
• our suppliers and service providers for the purposes of providing services to us or directly to you on our behalf. Such third parties may include cloud service providers (such as hosting and email management) and administrative services. When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions

5. WHERE WE STORE YOUR PERSONAL INFORMATION 

All information you provide to us is stored on our secure servers which are located within the European Economic Area (EEA), and/or the United Kingdom (if at any point the United Kingdom ceases to be within the EEA).

If at any time we transfer your personal information to, or store it in, countries located outside of the EEA (for example, if we use Microsoft Azure servers in the USA or our hosting services provider changes) we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law. This is because some countries outside of the EEA do not have adequate data protection laws equivalent to those in the EEA.

6. HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR

If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain personal information in an identifiable format for longer than is necessary.

We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under How we use your personal information above. The only exceptions to this are where:

• the law requires us to hold your personal information for a longer period, or delete it sooner;
• you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further Erasing your personal information or restricting its processing below); or
• in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.

7. SECURITY AND LINKS TO OTHER SITES

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to the App and any transmission is at your own risk. Once we have received your personal information, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access. As we also collect victims’sensitive personal information as part of the App, we apply a high level of security controls to protect all of your personal data.

Where we have given (or where you have chosen) a password which enables you to access an account, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

8. COOKIES

Like many other mobile apps and websites, the App may use cookies (including Google Analytics cookies to obtain an overall view of visitor habits and visitor volumes to the App). 'Cookies' are small pieces of information sent to your computer or Device and stored on its hard drive to allow the App to recognise you when you visit. It is possible to switch off cookies by setting your browser preferences. 

9. YOUR RIGHTS

You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either (i) the date that we have confirmed your identity or (ii) where we do not need to do this because we already have this information, from the date we received your request.

Accessing your personal information

You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

Correcting and updating your personal information

The accuracy of your information is important to us. If you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know or update your profile information directly in the App. 

Withdrawing your consent

Where we rely on your consent as the legal basis for processing your personal information, as set out under How we use your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you withdraw your consent, our use of your personal information before you withdraw consent is still lawful.

Objecting to our use of your personal information and automated decisions made about you

Where we rely on our legitimate business interests as the legal basis for processing your personal information for any purpose(s), as set out under How we use your personal information, you may object to us using your personal information for these purposes. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data. You may also contest a decision made about you based on automated processing.

Erasing your personal information or restricting its processing

In certain circumstances, you may ask for your personal information to be removed from our systems. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request. You may also ask us to restrict processing your personal information where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings. 

Transferring your personal information in a structured data file (“data portability”)

Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under How we use your personal information, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file. You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

Complaining to the UK data protection regulator

You have the right to complain to the Information Commissioner’s Office (ICO) if you are concerned about the way we have processed your personal information. Please visit the ICO’s website for further details. If you have any concerns about the way we have handled your personal information, we encourage you to contact us and we will seek to resolve any issues or concerns you may have.

10. CHANGES TO THIS POLICY

We may review this policy from time to time and any changes will be notified to you by posting an updated version on the App and by notifying you next time you start or login to the App. We recommend you regularly check for changes and review this policy whenever you visit the App. If you do not agree with any aspect of the updated policy you must immediately notify us and cease using our services.

11. CONTACT US 

If you have any queries about this Privacy Policy or the way we use your personal information, or if you would like to exercise any of your rights as listed above, please contact us using the contact details below.

admin@anatomap.com

David Scoggins

Data Protection Officer and Head of Compliance

Innovation House, 19 Staple Gardens, Winchester, Hampshire, SO23 8SR