Consentry is a privacy centric solution, firstly for businesses, employers and organisations to assist business continuity through a pandemic, enabling a healthier workforce and providing a safer work environment and secondly for individuals by enabling prompt and reliable delivery of COVID-19 or other test kit results to an individual’s device and the production of test result certificates. Consentry is a collaboration between UK-based digi.me Limited (“digi.me”) and Netherlands-based DutchSec B.V. operating under its brand name DTACT (“DTACT”).
The Consentry solution comprises two elements; firstly, a client (iOS or Android) application (“Client Application”), (used by individuals, employees or members and referred to in this Privacy Notice as “Client Users”), secondly a web-app Portal (“Portal”), including a dashboard (used by employers, businesses or organisations and referred to in this Privacy Notice as “Organisations”) and thirdly a processing and storage back-end. For some Organisations, customers and/or visitors will also be Client Users.
The Client Application enables a Client User to create a private, secure and encrypted personal data vault on his iOS or Android device. The Client User can input and store self-assessment information, create a location diary by QR code check-in/check-out, pass anonymised data to the Portal database and receive private alerts if suspected of coming into contact with infected co-workers, visitors etc.
The Consentry dashboard enables an Organisation to monitor the work environment by aggregating anonymised data received from each Client User’s Consentry Client Application. The dashboard then provides decision-enabling trends such as the number of employees showing virus symptoms, actually infected or exposed to an infected person and identify potential hotspots within physical facilities. Businesses can then proactively take both preventative and reactive actions based on the insights gathered such as providing information so that only the relevant staff need to self-isolate and undergo testing or for the business to arrange for a particular location to be closed/deep cleaned
Consentry is provided to an Organisation on a Software as a Service (SaaS) basis. The contractual relationship for that Organisation is with the legal entity that has sold the Organisation the SaaS, either digi.me or it subsidiary, digi.me B.V. based in the Netherlands.
Irrespective of any contractual relationship, the SaaS solution is provided by digi.me and it is digi.me that has overall responsibility for this Privacy Notice. For the purposes of this Privacy Notice and the Consentry terms & conditions, DTACT is a subcontractor to digi.me. Madison CI Pte. (Madison) in Singapore is in turn a subcontractor to DTACT. Digi.me, DTACT and Madison are bound by the terms of this Privacy Notice.
For an Organisation to register to use the product, Personally Identifiable Information (“PII”) needs to be input into the Portal. All Portal data is by default stored within the EU (currently an AWS server in France). The Organisation is the controller of that Portal data. Digi.me is the processor of that information.
The Organisation will input further PII into the Portal relating to Organisation administrators and Client Users. The Organisation also invites Client Users by email to use the Consentry Client Application. The Organisation is the controller of that Portal data. Digi.me is the processor of that information.
On download and use of the Client Application, the Organisation’s Portal is notified that the individual is now using the service. The Organisation is the controller of that Portal data. Digi.me is the processor of that information.
The Client User is able to share privately their daily health self-assessments anonymously with the Organisation. Sharing is only possible with the consent of the Client User. No PII is passed between the Client User’s device and the Portal relating to those self-assessments.
The Client User uses the Consentry client app to record their location history by scanning QR codes. That data does not leave the Client User’s device.
On learning that a location has been visited by an infected person, the Organisation sends out the time/location details to the Consentry client app of all Client Users registered with that Organisation. No PII is contained in the transmission to a Client User’s device.
On receipt of a potential infection message, the Client User’s Consentry app will review the Client User’s location history and either discard the message or warn the Client User, dependent on whether an element of the location history matches the parameters of the potential infection message. Neither the warning message, nor the fact it has appeared, leaves the device, but the warning message details what the Client User needs to do, including contacting the Organisation.
A Client User is able to edit their location history and also privately share that history with the Organisation, should they be diagnosed as infected during a pandemic. Sharing is only possible with the consent of the Client User. PII is passed between the Client User’s device and the Portal. On receipt of that PII by the Portal, the Organisation is the controller of that data, digi.me is the processor.
Data exchanges from the Portal to the client app and from the client app to the Portal are direct, using normal internet routing. Data is only routed and not further processed during these exchanges.
Data processed by an Organisation, or shared by that Organisation with third parties, is covered by that Organisation’s own Privacy Notice.
On expiry of an Organisation’s licence:
a) All PII held in the Portal database for that Organisation, including any PII privately shared with that Organisation by Client Users, will be deleted after 60 days, except any information retained for statutory or legal reasons, as covered by the data retention policy below.
b) Client User data will be retained on the Client User’s device and the Client Application will continue to function. The Client User will be able to record health self-assessments, but not submit these to their Organisation. Additionally, the Client User will be able to retain and add to their location history.
Independently of any other functionality and whether or not connected to an organisation, a Client User is also able to register a COVID-19 or other test kit by scanning the test kit QR code and consenting to share relevant PII input by the Client User with a government’s health authority if the test is positive, thereby enabling health authority trace and trace activities. Without that consent, the test kit cannot be registered. No PII leaves the Client User’s device on registration of the test kit.
The test kit ID is held on the secure Consentry back-end and matched against the test result information sent by the testing laboratory. The result of the test is sent to the Client User’s device. If the test is positive, the relevant PII required by a government’s health authority is returned to the Consentry back-end and then passed to the government’s health authority. The testing laboratory is the Data Controller, digi.me is the Data Processor and DTACT a Data Sub-Processor in these data exchanges.
Using the test result information sent to the Client User’s device, the Client User is able to produce a pdf certificate of the negative or positive test result on the device, with the test result data being combined on the certificate with the PII input into the device by the Client User. The processing of the data to produce that pdf certificate takes place on the Client User’s device. All data remains under the control of the Client User during this process.
At digi.me (“we”), we understand that we have a responsibility to look after any PII and to protect and respect the privacy of that PII. PII is securely stored using a high level of encryption.
There are however legitimate reasons why we may have personal data about an individual employed by or associated with the Organisation (“you”). The following part of this Privacy Notice describe how we may collect and use your personal data, the reasons why we may need to disclose your personal data to others and how we store your personal data securely, compliant with the General Data Protection Regulation (GDPR). Digi.me may be both a data controller and a data processor of your personal data.
Digi.me Limited is registered in England and Wales as a limited company under registration number 6861219 with its registered office at 7 Bower Road, Wrecclesham, Farnham, Surrey GU10 4ST, United Kingdom.
The digi.me Data Protection Officer (DPO) is the company’s Chief Financial Officer. If you have any questions regarding this notice or would like further information about the personal data digi.me may hold on you and the way in which digi.me may process that data, please email DPO@consentry.com.
We obtain personal data about you when for example you:
Sign up for our user, business or partner newsletters;
Sign up as a beta user, a tester, join our insider programme or use Apple Testflight;
Submit a bug report to us via Instabug or other reporting system or submit a support ticket via Freshdesk or other support system;
Complete forms on our website;
Enter a competition, promotion or survey;
Attend a hackathon or other event;
Request further information from us on in respect of the services we provide;
Contact us by email, post, telephone or social media;
Register your Organisation to use the Consentry solution;
Have a commercial relationship with us as a customer, supplier, business advisor, consultant or other service provider;
Make an employment application to us.
We may also obtain personal data about you for example from third parties and/or publicly available resources, e.g. Companies House.
The data we collect and hold you may include:
Your personal details such as your name, address, email address, phone numbers, payment information, IP address etc.;
Your career history or other data if you are making a job application;
Information on your use of the Consentry application, session data etc.;
Any communications that have taken place between us;
Details of contact we have had with you in respect of the actual or proposed provision of services to you or from you;
Details of any services you have received from us or provided to us;
Information about any complaints & enquiries you have made to us or us to you;
We use information about you in the following ways:
To process enquiries, non-disclosure or other agreements or orders you have submitted to us or us to you or for the performance of any contract we have with you or you with us;
To comply with our legal obligations and any contractual obligations we have with you;
To provide you with products and services;
To enable us to review and improve our website, applications and services;
To provide customer support, including responding to your support requests;
To administer creditor or debtor accounts and process and track payments;
To carry out marketing and statistical analysis or where we seek your thoughts and opinions on the services we provide;
To notify you about changes to our website, terms & conditions, services or prices;
To process job applications;
• To provide you with information about our products and services that you request from us or which we feel may be of interest to you, provided you have consented to be contacted for such purposes.
We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.
We may process your personal data for certain additional purposes with your consent. In the limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected. When assessing what retention period is appropriate for your personal data, we take into consideration:
the requirements of our business and the services provided to you and the services you provide to us;
any statutory or legal obligations;
the purposes for which we originally collected the personal data;
the lawful grounds on which we based our processing;
the types of personal data we have collected;
the amount and categories of your personal data; and
whether the purpose of the processing could reasonably be fulfilled by other means.
We may need to keep your data for up to 7 years after any commercial arrangement has ended in order to satisfy our legal, taxation or accountancy obligations. We may also keep your data for research or statistical purposes. In all cases, your personal data will only be used for the purposes we collected it.
Where we need to use your personal data for another reason, other than for the purposes for which we collected it, we will only use your personal data where that reason is compatible with the original purposes. Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
Access to your personal data within our Organisation is limited to those who require access in order for us to fulfil the purposes for which we hold that data.
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so. For the avoidance of doubt, we do not and never shall sell your personal data to third parties for marketing, advertising or other purposes.
“Third parties” includes third-party service providers. The following activities may be carried out by third-party service providers: IT and cloud services, professional advisory services, administration services, marketing services and banking services. All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.
We may transfer the personal data we collect about you outside of the EEA where there are adequate measures in place to protect that data.
We may provide links to third-party sites. Since we do not control those websites, we encourage you to review the Privacy Notices of those third-party sites. Any information provided on those sites will not be within our control and we cannot be responsible for the privacy policies or the practices of those sites.
We take the security of your data and our own most seriously. We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
You have the right to object to our use of your personal data, or ask us to delete, remove or cease using it if there is no need for us to retain it. This “right of erasure” is more commonly known as your right to be forgotten. There are however genuine legal and accountancy reasons why we will need to keep your data, but please do inform us if you think we are retaining or using your personal data incorrectly.
Our Privacy Notice will be made clear to you at any point of collection of your personal data. you will always have the right to ask us not to process your personal data for marketing purposes. If you choose not to receive marketing communications from us about our products and services, you will be able to make that choice by not opting in to receive such communications. We will not contact you for marketing purposes unless you have given us your prior consent through this opt-in process.
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by emailing DPO@consentry.com.
Under certain circumstances, by law you have the right to:
Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully;
Request correction of the personal data that we hold about you;
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. you also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below);
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third-party) and there is something about your particular situation which makes you want to object to processing on this basis. you also have the right to object where we are processing your personal information for direct marketing purposes;
Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it;
Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
If you want to exercise any of the above rights, please email DPO@consentry.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We apologise in advance for any delay that may arise from these security measures.
Where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (e.g. in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email DPO@consentry.com.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
This Privacy Notice may be updated from time to time. Any changes we make to this Privacy Notice will be updated on our website.
Should you have any questions regarding this Privacy Notice or would like further information about how we process your personal data, please email DPO@consentry.com.
You have the right to make a complaint to the Information Commissioner’s Office (ICO) about how we hold or process your personal data. The ICO’s contact details are:
Information Commissioner’s Office
Version 1.4, February 2021