Barbados and
countries around the world are currently battling the COVID-19 pandemic. In
Barbados, this has resulted in the Government of Barbados declaring a Public
Health Emergency.
This App has
been created by the Ministry of Health and Wellness, working with the Ministry
of Innovation, Science and Smart Technology and other key partners, as part of
Barbados' strategy for effectively managing the impact of COVID-19 on our
society.
This Privacy
Policy explains how we collect, use, disclose, and safeguard your information
when you use the App. Please read this Privacy Policy carefully.
1. What
does the App do?
2. What
information are we collecting from you?
3. What
is our legal basis for using your information?
4. Who
will we share your information with?
5. Will
your information be secure?
6. How
long will the information be kept for?
7. What
are your privacy rights?
8. What
about updates to this policy?
9. Who
do you contact about this policy?
The App
supports Barbados' national public health emergency response during the
COVID-19 crisis by allowing visitors and residents to safely and securely
monitor their own symptoms and self-report those symptoms. In the event that
you are concerned you might have contracted COVID-19, the App will help you
locate relevant health centres and other resources you may access for further
information, testing and/or treatment while in Barbados.
The App is
also a resource for information on requirements for travel to and from Barbados
during the COVID-19 pandemic, as well as for general data on the incidence of
the virus nationally and globally.
If you have
recently travelled to Barbados, the App will also seek to preserve the health
of others with whom you come into contact by connecting you to resources that
will enable contactless confirmation of information related to your travel.
When you sign
up for the App, we will collect your personal information including your name,
email address and telephone number. In the event you self-report that you have
symptoms consistent with COVID-19 [or you have come into close contact with
someone who has contracted COVID-19], your email address and telephone number
may be used to contact you.
We will also
generate a one-time password (OTP) to help you securely access the App on first
use.
If you
self-identify as a visitor to the island, we will also collect information on
your recent travel history and we will generate a unique QR code that is tied
to the other contact information you provide.
Health
information - if you utilise the symptom-monitoring features of the App, we
will collect information about the symptoms you are experiencing, the time of
day you are experiencing them, your age group, your name, your contact
information, and your gender. This information will be uploaded to the servers
of the Ministry of Health and Wellness of the Government of Barbados.
We will only
use your personal data where we have a lawful basis for doing so. In every
case, the legal ground will be one of the following:
â— Where
you give us your consent. You can
withdraw your consent at any time by contacting us via our contact details;
â— For
our legitimate interest, where it is
necessary for us to understand how users like you use the App, and to improve
the App;
â—
To comply with our legal
or regulatory obligations.
Any
information you share via the App with the Ministry of Health and Wellness,
Government of Barbados, will not be shared with other Government agencies
unless they are part of the overall strategy for responding to the COVID-19
Public Health Emergency. For example, if you have declared you have recently
entered Barbados, the App may be used to collect information which will be
shared with the Immigration and Customs departments of the Government of
Barbados in a contactless manner.
Information
you provide will be held in accordance with the standards outlined in the
Barbados Data Protection Act. Any personal information you share with the
Ministry of Health and Wellness, Government of Barbados, will be held securely
in compliance with the Government’s standards. We will ensure that appropriate
methods are utilised to safeguard your personal data from unauthorised access.
We will not
keep personal data longer than is required for the App to function
effectively. We will keep most personal data
for the entire time you use the App. In
some cases, we may retain personal information for longer if the law requires
us to do so.
In deciding
how long to keep your personal data, we consider the reasons why we hold it,
its sensitivity, how long the law requires us to keep it, and the risks
associated with retaining it.
The health
information we collect from you when you self-report will be kept for up to 60
days.
You have a number of rights under
the Data Protection Act, 2019-29 and the Electronic Transactions Act Cap 308B
of Barbados,. Except as limited under applicable law, these rights afforded to
you include:
â—
Right of access - the right to be informed of,
and request access to, the personal data we process about you;
â—
Right to rectification - the right to request us
to amend or update your personal data where it is inaccurate or incomplete;
â—
Right to erasure - the right to request us to
delete your personal data;
â—
Right to restrict - the right to request us to
temporarily or permanently stop processing all or some of your personal data;
â—
Right to object -
a. the
right, at any time, to object to us processing your personal data on grounds
that should we continue to do so, it will likely cause you damage or distress;
b. the
right to object to your personal data being processed for direct marketing
purposes;
â— Right to data portability - the right to request
a copy of your personal data in electronic format and the right to transmit
that personal data for use in another party’s service;
â— Right not to be subject to automated
decision-making - the right to not be subject to a decision based solely on
automated decision making, including profiling, where the decision would have a
legal effect on you or produce a similarly significant effect;
â—
Right not to have your information transferred
to any third party without your consent; and
â—
Right to withdraw your consent at any time in
respect of the processing of your personal data.
In order to
exercise any of your rights, requests should be made to covid19app@health.gov.bb.
We will
respond to any legitimate requests within one month. If your request is
unfounded, repetitive or excessive, or if we are not in a position to identify
you, we are entitled to refuse to act on your request.
This policy
was last updated on July 9, 2020.
From time to
time we may make changes to this policy to reflect changes in how the App
functions. If these changes significantly impact how we will process your
personal data we will alert you via email, if you have provided one to us.
At no point
will your rights be less than they are now.
Ministry of Health and Wellness,
Frank Walcott Building,
Culloden Road,
St. Michael,
Barbados,
+1 246 536-3800