Good Vibrations privacy policy WHO ARE WE AND WHAT IS THE GOOD VIBRATIONS PROGRAMME? Age NI is a private company limited by guarantee, with our registered office at 3 Lower Crescent, Belfast, BT7 1NR and our company number NI071940. We are registered with the Charity Commission for Northern Ireland, with number NIC104640 We are running a pilot programme called ‘Good Vibrations’ which is intended to promote and encourage better health and wellbeing among its participants. As part of the programme, volunteers will be asked to share health and wellbeing information which will be collected and stored in a private account on an online dashboard (the Support to Perform Platform). The data collected on the Support to Perform Platform will be analysed to enable us to provide volunteers with feedback relating to their wellbeing. WHAT IS THIS NOTICE ABOUT? In order to run the Good Vibrations programme, we will need to collect certain data from our applicants and volunteers, which is likely to include ‘Personal Data’ (that is, data from which a living person can be identified). As the controller of the data, it is our responsibility to make sure that you know what data we collect and how we will use any such data collected. That is what this notice is intended to do. This notice only provides information specifically relating to the Good Vibrations programme. It is intended to supplement (and not replace) our standard data protection policy, which can be accessed here: https://www.ageni.org/privacypolicy. For any additional details not set out herein, please use this link to access our standard policy or you can contact us using our contact details set out at paragraph 7 below. WHAT DATA WILL WE COLLECT FOR THE PROGRAMME AND WHERE DO WE GET IT FROM? (i) APPLICATION DATA: That is any information that you provide to us directly if you submit an application to take part in the Good Vibrations programme. This includes: identification data (such as your name and contact details) demographic data (such as your age and gender) health data (such as the existence of any medical conditions or issues which may affect your ability to take part in the programme and information about your level of physical activity) IT competence and connectivity data preference data (such as information about your preferences relating to data sharing and engaging in promotional activities) (ii) ACCOUNT DATA: That is information which we will require to set up and support an applicant who has been selected to participate in the Good Vibrations programme. This includes: Application Data (as defined above) which will be provided directly by you governance data (such as evidence of your acceptance and any consents given) which will be provided directly by you participation data (such as technical usage data, log in and account details). Any technical data will be collected automatically when you log in to or access the Support to Perform Platform. (iii) PHYSICAL ACTIVITY DATA: This is information collected automatically through your use of your Garmin physical activity device which once configured to do so, will send the data to your account on the Support to Perform Platform. The extent of the data collected will depend on the device you use, but is likely to include some or all of the following metrics: Number of steps taken and stepping frequency Number of floors climbed Number of calories burned Minutes of intense activity Heart Rate, used to assess sleep quality, stress levels and V02 max and physical activity age Activities (summaries only, type, duration, distance, heart rate) Body composition (mass, muscle mass, bone mass, body water, body fat) Pulse Oximetry (collected using red and infrared light sensors) (iii) 5 STEPS TO WELLBEING DATA: That is information which will be provided directly by you when you complete your daily questionnaire. This is likely to include information about activities relating to your wellbeing, specifically: Connecting Being active Taking notice Learning Giving (iv) PROFILE DATA: This is information which will be generated by us by converting your Physical Activity Data and 5 Steps to Wellbeing Data into a points system to assess and track your physical activity and wellbeing over the duration of the 12 week Good Vibrations programme. (v) FEEDBACK DATA: That is any feedback which you provide us with directly at the end of the Good Vibrations programme. HOW WILL WE USE THE DATA WE COLLECT? (i) TO SELECT VOLUNTEERS TO PARTICIPATE IN THE PROGRAMME. The selection process will be carried out manually by Age NI, using the Application Data. Applicants who are not selected may receive an email from us confirming that they have not been selected on this occasion. Any such applications will be destroyed within 14 days of the decision. Applicants who are accepted will receive an email confirming that this is the case. Copies of their Application Data will be retained for the duration of the Good Vibrations Programme and thereafter will be retained in accordance with our retention policies. For more information on this please see paragraph 6 below. (ii) TO ON-BOARD VOLUNTEERS. This will include using information included in the Application Data to set up an online account for a volunteer on the Support to Perform Platform. (iii) TO CREATE A WELLBEING PROFILE AND PROVIDE FEEDBACK FOR EACH VOLUNTEER. This will mean collecting and analysing Physical Activity Data and 5 Steps to Wellbeing Data to create points-based feedback which will be accessible to each volunteer via their private account on the Support to Perform Platform and which may also be emailed to a volunteer (iv) TO SEND NOTIFICATIONS EMAILS AND INVITES TO VOLUNTEERS RELATING TO THE GOOD VIBRATION PROGRAMME. This may include invites to webinars and online events and other educational content relating to physical activity and wellbeing. (v) TO CARRY OUT RESEARCH AND ANALYSIS. Aggregated data will be collected from the Account Data, Physical Activity Data, 5 Steps to Wellbeing Data, Profile Data and Feedback Data to enable us and our partners to analyse the data for research purposes as well as to evaluate the pilot programme. Any such data will be anonymised and will not include any personal data. (vi) TO MEET OUR REGULATORY AND LAWFUL REQUIREMENTS. We may retain and use information relating to the Good Vibrations programme to the extent necessary to meet our regulatory and lawful requirements and if necessary to defend and protect our interests. WILL WE SHARE THE DATA WE COLLECT WITH ANYONE ELSE? (i) SERVICE PROVIDERS: We have engaged Support to Perform Ltd to provide us with assistance in creating the Good Vibrations programme; to provide us with the Support to Perform Platform; and to help us to analyse and create feedback for our volunteers. Support to Perform Ltd is being engaged as a processor acting on our behalf and in accordance with our instructions. We may also engage other service providers to help us to deliver the Good Vibrations programme. (ii) FUNDING PARTNERS: The Good Vibrations programme is funded by Department of Communities. We will need to collect and share information with our funding partners to help them assess how their funds were used. Any such reports which we collate on their behalf will only include aggregate data. No personal data relating to our volunteers will be shared for this purpose. (iii) GARMIN: We will not share any of the information which we collect as part of this programme with any other businesses (including Garmin) for commercial purposes. However, we would ask you to be aware that the Garmin physical activity devices are provided by a third party, which will have its own privacy and which is not bound by the terms set out in this notice. You should check Garmin’s privacy notice before using their (or anyone else’s) physical activity device as part of this programme. You can find more information about our data transfer policies in our general privacy policy which is accessible here: https://www.ageni.org/privacypolicy. RETENTION PERIODS (i) APPLICATION DATA - For those applicants who are not selected to act as volunteers for the purposes of the Good Vibrations programme, we will delete all Application Data received within 14 days of a decision having been made. - For those applicants who are selected to participate as volunteers, we will retain their Applicant Data for the duration of the 12 week Good Vibrations programme. We may need to retain this information on file for a period thereafter in case any matters arise in connection with the pilot in the future. If we do so retain the information, we will only do so to the extent necessary to meet our regulatory and lawful requirements and if necessary to defend and protect our interests. (ii) ACCOUNT DATA, PHYSICAL ACTIVITY DATA, 5 STEPS TO WELLBEING DATA and PROFILE DATA will be retained for the duration of the 12 week Good Vibrations programme and deleted within 14 days of completion of the same. (iii) AGGREGATED DATA (anonymised data collected from each volunteer’s participation with the programme and feedback) will be retained on an ongoing basis. Any personal data which we hold and process for the purposes of running this pilot programme is held on the basis of your consent. You are entitled to withdraw your consent at any time and ask us to stop processing data for this purpose. For more information on this please see paragraph 7 below which sets out your legal rights and how to contact us. 7. YOUR LEGAL RIGHTS AND HOW TO CONTACT US You reserve the right to tell us at any time that you no longer wish to participate in the Good Vibrations programme and we will stop processing any data relating to you for such purposes. Since the Garmin physical activity device has been provided to you in exchange for your agreement to participate, we may request that you return the device to us. Under certain circumstances, you may also have rights under data protection laws in relation to your personal data including the right to receive a copy of the personal data we hold about you. More details relating to your rights can be found in our general privacy policy which is accessible here: https://www.ageni.org/privacypolicy. Should you wish to you can contact us at any time to ask about your rights and any other matters relating to the Good Vibrations programme and our use of data relating to you, please do so using the following details: by email to [email protected] by writing to Age NI, 3 Lower Crescent, Belfast, BT7 1NR alternatively, you can telephone 028 9024 5729. You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues. If you are not happy with how we have dealt with any enquiry from you relating to use of your personal data, you may contact the ICO. More details are available by following this link: https://ico.org.uk/make-a-complaint/ .