My mHealth mobile app (FOI)

Request

The Government of Jersey recently announced the launch of a mobile app for Health and Community Services patients which is described as "a free-to-use digital app that helps them to track, manage and understand respiratory, cardiac and diabetes conditions." The announcement can be seen at the link below:

Health app launched for Islanders with long-term conditions

That app contains third-party advertising and marketing software packages which are used to "Earn more revenue with your apps" and proclaims they can "Maximize the value of every impression across all your networks with the most advanced monetization technology."

A

With this in mind, I request a copy of the data protection impact assessment the Government of Jersey produced before deploying this app, as required for high-risk processing under the Data Protection (Jersey) Law 2018.

B

Please also supply any documentation which describes how Health and Community Services patient data will be used to "earn more revenue" by using "the most advanced monetization technology".

Response

A

Please see attached a copy of the Data Privacy Impact Assessment. Personal information has been redacted in compliance with Article 25 of the Freedom of Information (Jersey) Law 2011. However, it is noted that minimal personal information has been redacted. Such redactions are limited to the names and roles of less senior members of staff.

Data Privacy Impact Assessment - MymHealth (redacted) 

B

The Scheduled Public Authority has confirmed as follows:

• the My mHealth app does not contain any third-party advertising or marketing software.

• the My mHealth app does not monetize any of the information provided by patients.

• the My mHealth app complies with the Jersey Data Protection (Jersey) Law 2018.

Article applied

Article 25 Personal information

(1) Information is absolutely exempt information if it constitutes personal data of which the applicant is the data subject as defined in the Data Protection (Jersey) Law 2018.

(2) Information is absolutely exempt information if – (a) it constitutes personal data of which the applicant is not the data subject as defined in the Data Protection (Jersey) Law 2018; and (b) its supply to a member of the public would contravene any of the data protection principles, as defined in that Law.