My Liver Health App

Effective: April 27th 2022

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 Android and iOS My Liver Health App (“the App”) and the underlying research platform (“the Platform”).

Flinders University is responsible for hosting and maintaining this Site, the App and the underlying platform (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 Privacy Policy explains how your information is collected, used and protected. By accessing and using the Services, you agree to be bound by the terms of this policy. We encourage you to read this policy carefully to help you to make informed decisions about sharing your information with us.

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: phit@flinders.edu.au

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, mobile phone number). 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.

User feedback

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, mobile phone number). It also includes any information that may be used to reasonably identify you.

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 data with anyone.

Sensitive information

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 any data shared by your phone such as your IP address and device ID.

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 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 data is encrypted in a non-human readable format before it is transmitted from your device.

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.

Log information

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.

Cookies

We use cookies to make your use of our Services as convenient as possible. Cookies do not personally identify you; they are pieces of information that a site transfers to your computer’s hard disk for record-keeping purposes. We can also use cookies to monitor the amount of people using our Services and how they are using it. You can set your browser to refuse cookies but this may mean you cannot log in or take full advantage of our Services.

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 phit@flinders.edu.au to let us know.

Health information

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.

Other uses

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.

Emails

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

We may provide links to various third party sites. Any information you provide to third party sites will be governed under the terms of each site’s privacy policy and terms of use. We accept no responsibility or liability whatsoever for the content, actions or policies of third party sites. The inclusion of links to third party sites in our Services in no way constitutes an endorsement of the third party sites’ content, actions or policies: you access them at your own risk.

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: privacy@flinders.edu.au; or Post: The Privacy Officer, My Liver Health App Integrity, Governance and Risk Division GPO Box 2100 Adelaide, 5001

We will endeavour 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?

You can cancel your registration at any time. After you have cancelled your registration you will not be able to sign into the Services to view or access any information. Information about you collected on the site or by our Services prior to your deregistration will continue to be used by us in accordance with the Privacy Policy unless you contact us and request that we not use it.

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

As we evolve and introduce new services and features, our policies will be reviewed and may be revised. We reserve the right to change our Privacy Policy at any time and notify you by posting an updated version of this policy on our web site and within our Services. The amended Privacy Policy will apply when it is posted on our web site or available within our Services. Please review the Privacy Policy in place from time to time and if you don’t agree with any part of this policy, you should cancel your registration with our Services.