DrinksRation - Privacy Policy

Who are we

DrinksRation is managed by the King’s Centre for Military Health Research (KCMHR) which is the leading civilian United Kingdom (UK) centre of excellence for military health research. KCMHR is independent of the UK Ministry of Defence (MoD), and our work has helped shape government policy towards military personnel, veterans and their families.

Our research is conducted within the KCL governance framework and General Data Protection Regulation (GDPR). This ensures that our work is carried out to high scientific, ethical and legal standards.

Study background

DrinksRation was setup in 2016 by KCMHR to explore the development of a digital technology platform to support the Armed Forces community manage alcohol misuse. The feasibility study, which was conducted between 2016 and 2017 had 31 veterans contribute to the design, development and functional of DrinksRation. In 2022 we published the results of a Randomised Controlled Trial which demonstrated the effectiveness of DrinksRation.

Who is the data controller for DrinksRation

KCMHR will act a data controller. This means that we are responsible for looking after your data, keeping it secure and using it properly.

What information are we collecting

We are interested in collecting information related to how you consume alcohol, your mental health and physical activity. We will use this information to evaluate DrinksRation effectiveness in reducing alcohol misuse, and to customise your DrinksRation experience. We collect the following groups of data:

You can change which data group you share with us via DrinksRation at any time.

We operate a data minimisation policy. This means we only collect enough data to enable us to deliver the DrinksRation service.

Please note that we are not responsible for any third-party services. Please read specific privacy policies are these services.

How will my data be used

We will use the data you provide to conduct academic research. All research will require ethical approval for a suitable body/organisation. We will publish the findings in scientific papers and we will publicise them in the veterans’ and Armed Forces communities, e.g. by making them available for relevant newsletters and websites. We will inform the MoD and the NHS Armed Forces team of top-level results so that support can be put in place for Armed Forces Community and their families. We will also inform organisations responsible for public health.

Scientific papers will contain only anonymous, aggregated data (e.g. percentages and averages) presented as tables and figures. The scientific papers will not contain any data on individual users.

Your data will not be shared with any third-party organisation without your explicit consent.

How long will we hold the data

KCMHR will keep the data you provide for 7 years after your last data entry. If, in 7 years, no future analyses are planned, or you have not used DrinksRation, all the data we hold will be securely destroyed.

How do we keep your information safe and secure

Data collected via DrinksRation is sent to our servers using encrypted (secure) data transfer protocols. All electronic information is held securely on encrypted servers. Access to data is strictly limited to authorised members of KCMHR team.

The data we collect will only be used for the purpose of research. It will not be used to make decisions about future services available to you, such as insurance.

All our data is stored in accordance with the NHS Digital Data Protection and Security Toolkit framework (Reference: EE133874-MHR).

What is the legal basis for holding these data

The lawful basis for processing this information is: Article 6(1.e) of GDPR: processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

The special condition category is article 9(2)(j) of GDPR: processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) based on Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

DrinksRation enables you to select the types of data you share with us. You have the right to restrict our use of your personal data. This can be done by the 'Permissions' page.

How can correct/rectify the data we hold about you

If you believe that the data we hold about you is incorrect, you can contact Dr Daniel Leightley ([email protected]) with the data which needs to be updated and the reason(s). All legitimate requests will be actioned within 14 days.

How can you access your own data

You have the right to see the information we hold about you. You can contact Dr Daniel Leightley ([email protected]) for further information. All legitimate requests will be actioned within 14 days.

If you have opted out of data sharing via DrinksRation . We are unable to provide you with a copy of your data. This is because all data is stored on your device and not shared with us.

How can you delete of your data

You have the right to request that the data we hold on you is deleted. You can request that we delete your data via the 'Delete Account' section of 'Accounts' page. Once you have made the request, all data is automatically deleted within 24 hours. This is an automated task and data can't be undone.

How can I object to my data being used

Article 21 of the GDPR gives individuals the right to object to the processing of their personal data. If you wish to object to your personal data being processed please email your reason(s) to the KCL Data Protection Officer: Ms Olenka Cogias (Assistant Director of Business Assurance) Information Compliance team, King's College London, Waterloo Campus Room 5.20, James Clerk Maxwell Building, 57 Waterloo Road, London, SE1 8WA; or by email: [email protected] All legitimate requests will be actioned within 14 days.

You can opt-out of data sharing at any time via the 'Data Sharing' page of DrinksRation .

Complaints

If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter. If you are not satisfied with our response or believe we are processing your personal data in a way that is not lawful you can complain to the Information Commissioner’s Office (ICO).

Our Data Protection Officer, Ms Olenka Cogias (Assistant Director of Business Assurance), can be contacted at Information Compliance team, King's College London, Waterloo Campus Room 5.20, James Clerk Maxwell Building, 57 Waterloo Road, London, SE1 8WA; or email: [email protected]

Underage use and lack of consent

If you believe that a child is using DrinksRation please contact Dr Daniel Leightley ([email protected]).

General enquiries

For general enquiries relating to the study, or to find out more about how we use your information please contact Dr Daniel Leightley ([email protected]) for more information.

Updates

Our Privacy Notices are regularly reviewed and updated. Should the lawful basis in how we process your information change, we will notify you in DrinksRation and seek your consent.

Date last reviewed: 20/07/2022 (Dr Daniel Leightley)

Date last updated: 20/07/2022