Babylon Privacy Policy

Hello

Welcome to the Babylon privacy policy.

We take your privacy seriously. We want you to know why we need certain information from you, what we're doing with it, and how we keep it secure.


1. What this policy covers

This policy explains how we use your data where you use our app, websites and services as part of our collaboration with The Royal Wolverhampton NHS Trust (“RWT”) to provide a digital primary care service to registered patients with its collaborating GP practices in Wolverhampton (“RWT users”).

Under the collaboration between Babylon and RWT, RWT and its clinicians provide the consultation services.

Babylon's services consist of (a) the technology to enable these consultations and (b) the digital healthcare tools accessible through the Babylon app.

Babylon is the data controller for your Babylon account registration information and your use of Babylon’s digital tools, such as Symptom Checker and Healthcheck. Babylon does not share your personal data relating to your use of its digital tools with RWT.

RWT is the data controller for your consultations.

Where you have consultations with RWT clinicians via the Babylon app or website, Babylon will be a data processor for your consultation experience with RWT clinicians. In this instance, we provide the technology to RWT (the data controller for the provision of your care) to enable their clinicians to consult with you. If you have questions regarding the processing of your data by RWT in these instances, please refer to RWT's applicable Privacy Notice.

Where you are an RWT user, this policy applies to you, instead of the standard Babylon privacy policy (https://www.babylonhealth.com/terms/privacy) which will apply if you choose Babylon’s private services, or your eligibility for RWT services via the Babylon app ends.

For the purposes of this policy, “we”/”us” means Babylon Partners Limited, a company registered in England with company number 08493276. Our registered office is 1 Knightsbridge Green, London SW1X 7QA.


2. What data we hold and how we get it

Personal data is any information we have that can identify you, such as your name, medical history

Personal details

When you register with us, we'll ask you for your:

  • Name
  • Date of birth
  • Address
  • Email address
  • A copy of your ID (identity documentation), such as a driving licence

The information you give us must be accurate. If you give us information about yourself or another person, you're confirming that you're authorised to do so.

Health and medical data

  • When you use our services, we collect information about your health, including: Interactions with our services, like using our Symptom Checker or other digital services. These interactions may be shared with our clinical staff so that we can provide you with healthcare, and so that we can provide a better experience

If you’re an RWT user, who has a consultation with RWT via our app, we’ll process your consultation information on behalf of RWT as a data processor. This could include:

  • Symptoms, treatments and medications
  • Consultations, such as notes and recordings
  • Procedures, such as surgery, scans or X-rays

RWT will store your consultation notes on RWT’s own systems.

Some of this information comes directly from you, but it can also come from third parties, such as your GP. We share children's appointment notes with their NHS GP, in line with current medical guidelines.

Details of your conversations with us

We also keep an audio record of your consultations and your conversations with us or RWT clinicians. This is so we, or RWT (who may consult with you and are responsible for your care), can access your consultations to monitor the quality of our service and healthcare.

We keep your health and medical data secure by applying technical and organisational measures to protect it.

Find out how long we keep your data.

Data from other sources

We might also receive some data about you and your health from other apps, devices and services.

This will only happen if you've agreed to sharing that data with us. For example, if you decided to share information collected from a smartwatch with our app.

Technical information and analytics

When you use our app, or visit our website, we may collect the following data, where this is allowed by your device or browser settings:

  • The IP address used to connect your mobile phone or other device to the internet
  • Your browser information, such as Google Chrome or Apple Safari
  • Login and operating system
  • The make and model of your device
  • Resettable device identifiers
  • Time zone, language and location settings
  • Your mobile network provider and your location (based on your IP address)
  • Information about your visit to our website or use of our app, for example when you first visited the site or how many times you've visited
  • Information about the products or services you viewed or used
  • App response times and updates
  • Information about your interactions, like what notifications you opened
  • Any phone number used to call our customer service number

Babylon works with other companies that provide us with analytics and advertising services. This is to:

  • Help us understand how people interact with our services
  • Provide the adverts for our services on the internet
  • Measure the performance of our services and our adverts

Your health information is not used for these advertising services.

Cookies

We also use 'cookies'. Cookies are files saved on your phone, tablet or computer when you visit a website. They collect information about how you use the website and the pages you visit. We do not use cookies on your medical or health information. You can find out more about how we use cookies in our cookie policy.

Information from third-party services

It's possible to connect your social media accounts, or your wearable device (like a smartwatch) with our services. If you choose to do this, we'll receive the following information about you from the third party:

  • Name
  • Email address
  • Username or ID
  • Health and lifestyle habits and information

If you use login details from third parties, they will also process your login data, and they are solely responsible for handling this. We may also get information from other sources, such as companies who offer information on consumer trends.

We use this information to help us make our services better. We comply with data protection laws when we do this. If this information is used alongside your personal data, we will make sure that our interests never come before your rights. If you have questions about the way your data has been handled, please contact DPO@babylonhealth.com.


3. What we use your data for

This is how we use your data and the legal reasons for using it.

Providing you with a service

We need your personal information to enter into a contract with you and deliver services. This information is based on:

  • Providing you or planning for healthcare services in our 'legitimate interest'
  • Your consent to your NHS GP (for example, when you use our private service and agree to sharing information with your NHS GP)
  • The health and medical information we use includes information from your use of products like Symptom Checker and Healthcheck

We might share this information with RWT, as needed. This is so we can give you the right care, including when it's in your vital interests. These services include:

  • Your GP
  • Our NHS or clinical service partners, particularly when we are acting as a service provider on behalf of a partner who you will consult with (like RWT)

We use your location to recommend services near you, like pharmacies and hospitals. Depending on how you access our services, we get your location from your phone, internet browser, IP address or postal address.

Improving Babylon's services

If you've given explicit consent, we use your health and medical information to improve our services, including our artificial intelligence systems. This helps us deliver better healthcare to you and other Babylon users.

We remove details that could identify you from this information, such as your name, address and contact details. These are called 'personal identifiers'. The health and medical information we collect (with your personal identifiers removed) includes information from your use of products like Symptom Checker and Healthcheck

This doesn't involve making any decisions which would have a big effect on you. We only use this information to deliver a better experience to you and other Babylon users. This explicit consent relates to when we use your personal data. This does not include information that Babylon processes on behalf of RWT, to enable your consultations with RWT.

Helping health research

If you've given explicit consent, we use your data for health research. For example, to better understand health behaviour, disease risk or health outcomes.

We aim to publish our research results in peer-reviewed journals or by working with academics. We may conduct research with partner organisations such as universities or other academic institutions.

The type of information we collect includes use of products like Symptom Checker and Healthcheck We remove any details that could identify you from this information. This includes your name, address and contact information.

Our research follows the Declaration of Helsinki ethical principles, which were developed by the World Medical Association. As part of our research, we may use your contact details to invite you to take part in clinical trials. These trials might be about things like how frequently we give you medicine reminders or what exercise has the greatest impact on mood. This does not include information that Babylon processes on behalf of RWT, to enable your consultations with RWT.

Using your data when it's in our 'legitimate interest'

We sometimes analyse your data and how you use our products to help us manage our business better.

This could be things like fixing bugs in our app, understanding current user trends, or working out what users might want in the future. This doesn't involve making any decisions which would have a big effect on you. If this information is used alongside your personal data, we will make sure that our interests never come before your rights.

Keeping you up to date

We may contact you when marketing our service. This includes sending you product updates, surveys and marketing information. You can opt in or out at any time by going to 'Me', 'Settings' and 'Privacy Controls' in the app. You can also choose if you want to get app notifications in your device settings. This does not include marketing from RWT.

As part of providing you with a healthcare service or public service, we may send you health information by text message, email or in other ways. For example, we may send you public health messages or invite you to book an appointment for a free screening programme, such as cervical cancer screenings.

Regulating the quality and safety of our service

We use your health and medical information for safety, training, regulatory, and compliance purposes.

This means that:

  • If we're legally required to, or asked by a regulator, we may need to share your information with regulatory bodies like the General Medical Council, Medicines and Healthcare Products Regulatory Agency or Care Quality Commission
  • We may audit how you use our services, for example to review the quality of results provided by our products


4. How we store and move your data

Personal health and medical information

Your personal health and medical information is stored on secure servers. This includes information like:

  • Your primary care information
  • Information about your medications
  • Any information about a diagnosis of illness or other problems

We don't store any of this information on your mobile device.

If you've chosen a password or authentication method to access the app, you're responsible for keeping this password and/or authentication method confidential. Please don't share it with anyone. We encrypt data transmitted to and from the app. Once we have your information, we use strict procedures and security features to try to prevent unauthorised access. We will take all steps reasonably necessary to make sure that your data is treated securely.

Where we store and process your data

Your data may be processed or stored outside of the UK. This is because we sometimes work with other companies who help us deliver Babylon services to you. This includes software providers, hosting service providers and vendors that supply IT and other tooling to help us to deliver our services. These companies might have servers outside of the UK. Processing of information will always be in line with applicable data protection lawful mechanisms (such as appropriate contractual terms) and subject to strict safeguards.

For further information on how we protect your data if we transfer it outside of the UK, contact us by email at: DPO@babylonhealth.com.


5. How and why we share your data

To help us deliver our services we may share your personal data with RWT, who we work jointly or in connection with to provide you a service.

Service providers

Some companies provide services to you on our behalf, such as the live chat. We may share your personal data with them so that they can process it to provide these services.

These companies can only use your data based on our instructions and they cannot use the data for their own purposes. They also have to act in line with data protection laws and contractual terms that specify how they can process data on our behalf.

Protecting public health

We might process your health data to protect public health. Your data could be vital to help research, monitor, track and manage public health emergencies, like pandemics.

In a public health emergency, your information may be shared in a way that is appropriate and lawful with organisations such as:

  • NHS Digital
  • NHS England and Improvement
  • Public Health England
  • Local authorities
  • Health organisations
  • GPs

We will limit the use or sharing of data to the period of the emergency and will only share data to the extent necessary.

Aggregated or anonymous data

Babylon may show on our website or share with our commercial partners data that does not personally identify you, but which shows general trends. This is 'aggregated' data and is not personal data. This might include, for example, the number of users of our service or trends in a particular location.

Statistical data in the public's interest

We may also use data that does not identify you personally as part of statistics that we collect on certain types of illness, symptoms and conditions. This might include us contributing medical data and participating in the Royal College of General Practitioners Research and Surveillance Scheme.

We may show these summarised statistics to our partners. They will always be anonymised. This is so we can improve our medical knowledge and help our members and the general public.

This does not include information that Babylon processes on behalf of RWT, to enable your consultations with RWT. You can contact us directly if you do not want your data to be used in this way by email at: DPO@babylonhealth.com.


6. How long we keep your data

We follow advice from the Department of Health and the British Medical Association on how long to keep information found in your medical records. This is called a 'retention period'.

We might also keep some information that doesn't identify you to help improve our business and our services.

In some circumstances, we might keep data longer if the law says we have to. If you use Babylon to consult with an RWT clinician, and want information about how long RWT keeps your medical records, please refer to RWT’s privacy notices and policies.

Your information

How long we keep it (its 'retention period')

Symptom Checker

We keep your interactions with our Symptom Checker in the same way as your GP records.

They are also available in the app for 1 month (although that period of time could change if our product changes). After 1 month we can provide them if you ask us for them.

Healthcheck and Digital Twin records

We keep your records from these services for 2 years after you close your account, unless you agree to them being a part of your medical record. If you do, we will store them in the same way as your GP records. .

If you want to see any of this information while we have it (in its 'retention period'), you can ask for it by emailing us at: DPO@babylonhealth.com


7. Your rights

You're in control of your personal information. Under data protection law and when Babylon is acting as a data controller, you have the right to:

  • Remove or change your consent at any time, if we are using your data in a certain way based on it. You can do this by:
    • Going to the app, selecting 'Settings' and then 'Privacy controls'
    • Going to the Babylon Health website, selecting 'Your account' and then 'Privacy'
  • Ask for a copy of the personal data we hold about you. Your data is stored in line with our legal and medical obligations. See: how long we keep your data).
  • Ask us to correct information that's wrong, delete it, or ask that we only use it for certain purposes. There might be times when we're not able to help, like if the law or our medical obligations say we can't.
  • Ask us to restrict any automated (computer-made) decisions made with your data
  • Ask for your data to be provided in a portable format that allows you to move, copy or transfer it. Or ask us to send it in this format to someone else.

To do any of these things, please contact us at:

Data Protection Officer
Babylon Health
1 Knightsbridge Green
London
SW1X 7QA

Or by email at: DPO@babylonhealth.com

We'll ask you for a proof of identity. Data protection laws give us one month to get back to you. We're regulated by the Information Commissioner's Office (ICO). If you're not happy with any aspect of our data handling, you can complain to the ICO directly. You can contact them at:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Phone: 0303 123 1113

If you require information from RWT in relation to your consultations with RWT clinicians through the Babylon app or website, please contact RWT at: rwh-tr.IG-Enquiries@nhs.net or refer to the applicable RWT Privacy Notice.


8. Changes to this policy

We might update this policy from time to time.If we make any important changes, we'll let you know, and give you the chance to review them.

If you agree to the changes, you don't need to do anything. Just keep using our services with the updated policy and we'll assume you are happy with the way we use your data. If you agree to the changes, you don't need to do anything. Just keep using our services with the updated policy and we'll assume you are happy with the way we use your data. If you don't agree to the changes, then you can stop using our services at any time.