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.
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.
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:
● Where you give us your consent. You can withdraw your consent at any time by contacting us via our contact details;
● For our legitimate interest, where it is necessary for us to understand how users like you use the App, and to improve the App;
● 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:
● Right of access - the right to be informed of, and request access to, the personal data we process about you;
● Right to rectification - the right to request us to amend or update your personal data where it is inaccurate or incomplete;
● Right to erasure - the right to request us to delete your personal data;
● Right to restrict - the right to request us to temporarily or permanently stop processing all or some of your personal data;
● 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;
● 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;
● 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;
● Right not to have your information transferred to any third party without your consent; and
● 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 firstname.lastname@example.org.
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,
+1 246 536-3800