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Privacy Policy

OneSmallStep Privacy Policy

Contents of this Privacy Policy

 

  • About the OneSmallStep Privacy Policy & Our Commitment to Your Privacy
  • The Scope of this Privacy Policy
  • The Types of Information that We Collect
  • Our Reliance on Partners to Deliver OneSmallStep
  • Our Use of the Information That We Collect
  • Safeguarding the Information
  • Your Rights
  • Disclosures that are Required or Permitted by Law
  • Contacting Us
  • Effective Date & Communicating Changes

About the OneSmallStep Privacy Policy & Our Commitment to Your Privacy

 

Devon County Council is the sponsor of OneSmallStep (alternatively, “OSS”), a health & wellness information program, which is comprised of products and services offered by Optum Health & Technology (US) LLC and its affiliates ("Optum", "we", "us", "our").  Optum strives to properly address applicable data protection requirements.   We provide this privacy policy (“Privacy Policy”) to explain the Personal Information that Optum collects from users of OSS (“alternatively, users” or “you”,) and how we might use and disclose Personal Information.  

The Scope of this Privacy Policy

 

This OSS Privacy Policy provides you with certain important information about how we handle your Personal Information.  Optum Health & Technology UK Limited is the primary data controller for processing of Personal Information collected throughout OSS administration.  OSS makes available access to certain third-party applications that can provide additional assistance beyond OSS printed material, health & wellness content, and information regarding counseling sessions.  Additionally, access to third-party applications, such as those to assist with smoking cessation, reduction in alcohol consumption, and weight loss, might be made available.

 

THIRD-PARTY APPLICATIONS ARE NOT COVERED BY THIS OSS PRIVACY POLICY.  THIRD-PARTY APPLICATIONS ARE COVERED BY THE PRIVACY NOTICE MADE AVAILABLE TO YOU BY THE THIRD PARTY.  BEFORE YOU USE A THIRD PARTY’S APPLICATION(S), PLEASE READ THE THIRD-PARTY’S PRIVACY NOTICE CAREFULLY TO UNDERSTAND THE TYPES OF PERSONAL INFORMATION COLLECTED, THE PURPOSE OF THE PROCESSING, THE MANNER OF PROCESSING, AND YOUR RIGHTS IN YOUR PERSONAL INFORMATION.

The Types of Information that We Collect

 

You are not required to register to use the OSS website and access the self-help health & wellness content that is made available at its website.

 

If you use the OSS telephone operator service to access information, then we collect name, address, telephone number, email addresses, Post Code, gender, data of birth, General Practitioner, weight, smoking status, alcohol intake and other information relating to your physical activity.  We use this information to provide you with the printed material, health & wellness content, and other information that you might request, such as whom you may call to obtain the locations of counseling sessions in your area that can further help you to achieve your health & wellness goals.

 

Also, when you use the OSS website, we use automated means to collect information about you, your computer or other device that you use to access and use the OSS website.  These automated means include common technologies such as cookies or similar technologies.  These technologies help us to administer OSS, track users’ interactions, such as your interaction relating to the products and services, gather demographic information about our user base as a whole, and otherwise provide you with relevant content.  We collect information from and about the devices you use to access the OSS website, products and services. This includes information such as Internet Protocol (“IP”) addresses, the type of browser and device you use, the region and language settings on your device, and identifiers associated with your devices.  Where you have given consent, your devices, depending on their settings, may also transmit location information to us, to enable you to receive more relevant information from third party service providers and vendors acting on our behalf where you have agreed to receive such information.

 

We will also automatically collect, review and store information about your interactions with the products and services, such as page response times, page interaction information (such as scrolling, clicks, and mouse-overs), technical data (including crash reports), and the web page you visited before coming to our website or go to after our website.

Cookies and Tracking

Our website uses cookies. A "cookie" is a small file on your computer which may store information about your visit. For example, cookies help us recognize you as a prior site visitor, to enable website functionality, or to improve our website for your benefit.  Visit our Cookie Policy (below) to learn more.

 

By using our website you accept the use of cookies in accordance with our Cookie Policy. If you do not accept the use of cookies, please disable them by changing your browser settings so that cookies cannot be placed. If you disable cookies, you might not be able to use some of the functionality of our website.

 

We collect IP addresses in log files to analyze trends, administer our websites, track a user's movements across and within our websites, and gather broad demographic information for aggregate use.

Links

 

While visiting this website you may click on a link to other websites and leave this website. We provide links to other websites that may contain information that may be useful or interesting to you. We do not endorse, and are not responsible for, the content and accuracy of linked websites operated by third parties or for any of your dealings with such third parties. You are solely responsible for your dealings with such third parties and we encourage you to read the terms of use and privacy policies on such third-party websites.

Our Reliance on Partners to Deliver OneSmallStep

 

Optum relies on third parties (“Optum Partners”) who help us to deliver OSS.  We disclose information to them and Optum Partners also share information with us.  Optum personnel may access (on a need-to-know only basis) and process Personal Information in connection with their job responsibilities or contractual obligations.  Such access includes those individuals who are in charge of OSS administration, such as content management, quality management, business administration, and IT services and might also include senior executives and company managers.  Personal Information that we collect is processed (and stored) in United Kingdom.    We take appropriate steps to ensure that such entities are bound to duties of confidentiality and we implement measures such as standard data protection contractual clauses to ensure that any transferred Personal Information remains protected and secure.  A copy of these clauses can be obtained by contacting us at the address listed below in the “Contact Information” section.

Our Use of Information That We Collect

Use and Storage of Information to Provide You with the Website and Related Services

We and those acting on our behalf, may use and store your Personal Information to perform activities associated with providing you with the printed material, health & wellness content, and information regarding counseling sessions via the OSS website and telephone operators such as:

  • Resolving disputes and/or troubleshooting problems;
  • Improving the quality of the Website;
  • Fulfilling any request you make;
  • Communicating with you;
  • Connecting you with and providing you with information about services, providers of services, resources or programs to which you may have access (when requested via contact us page);
  • Providing you with Website content, including, without limitation, generating recommendations (such as recommended Website activities), and processing your preferences and requests;
  • Analyzing, customizing, and personalizing the Website, including through the delivery of tailored content and communications; and,
  • Otherwise as directed by you or provided for herein.

 

The legal basis of our Personal Information processing:  Our legal basis to process Personal Information includes processing that is:

  • Necessary for the our legitimate interests, including those described above;
  • Necessary for compliance with our legal obligations, including the provision of services to users;
  • Necessary for the establishment , exercise or defense of legal claims;
  • Necessary in order to protect the vital interests of the Participant of another natural person;
  • Necessary for reasons of public interest in the area of public health; or,
  • Based on consent by the Participants, which may subsequently be withdrawn at any time by contacting us at the address listed below in the “Contact Information” section without affecting the lawfulness of processing based on consent before its withdrawal.

 

Our reporting of aggregated, non-personally identifiable information or de-identified information:  Optum provide reports to Devon County Council (“aggregated reports”).  The aggregated reports demonstrate access of printed material, health & wellness content, and information regarding counseling sessions that is provided by OSS.  Only aggregated, non-personally identifiable information or de-identified information is included in the aggregated reports that we prepare.

 

You are not required to share your Personal Information:  You are not required as a statutory requirement to provide us with Personal Information for processing as described above.  When you do not provide us with Personal Information, we might not be able to provide the printed material, health & wellness content, and information regarding counseling sessions that you request.  

 

Direct Marketing: We will not use Personal Information that we collect from you for direct marketing purposes without obtaining your consent prior to doing so.  If you provide your consent for direct marketing, you can request to withdraw your consent at any time.  Each item of direct marketing will have instructions for withdrawing your consent to receive direct marketing.  You can request to withdraw your consent to direct marketing by following the instructions on the marketing material or by contacting us following the instructions in the “Contact Information” box below.

 

Note:  If you call our telephone operator service and request health & wellness information from OSS, we might forward information concerning the subject matter that you requested as it becomes available.  If you no longer want to receive the health & wellness information relating to your inquiry, simply call us and we will remove your name from the contact list.

 

Our Retention of Information:  Personal Information will be retained only for so long as reasonably necessary for the purposes set out in this Privacy Policy, in accordance with applicable laws.

Safeguarding the Information

 

We maintain reasonable security measures to safeguard Personal Information from loss, interference, misuse, unauthorized access, disclosure, alteration or destruction. We also maintain reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete and current.

Your Rights

 

You may contact us, at the address listed below in the “Contact Us” section, to request access to Personal Information we process about them, to correct any mistakes, or to request deletion of this data or to withdraw consent to the processing of Personal Information, in accordance with applicable law.

 

We might be unable to comply with your request where doing so would place us in breach of our obligations under applicable laws, regulation or codes of practice. However, in some circumstances, you may be able to request that your data be blocked from further processing. You might also have a right to data portability to another Data Controller under certain circumstances. Where we rely on consent to process Personal Information, consent may be withdrawn at any time, although the withdrawal may impact or disrupt the services we provide.  Whether we comply with your request or do not comply with your request, we will prepare a response within a reasonable period of time.  If you are aware of changes or inaccuracies in your Personal Information, you should inform us of such changes so that the Personal Information may be updated or corrected.  Participants may lodge a complaint with a supervisory authority if they consider that our processing of their Personal Information infringes applicable law.

Disclosures that are Required or Permitted by Law

 

Regardless of any other provisions in this Privacy Policy, we may disclose or otherwise process Personal Information in the context of any sale or transaction involving all or a portion of the business, or as may be required or permitted by law or required for the purposes of any regulatory audit to which we might be subject from time to time.

Contacting Us

 

By following the instructions below, you can request clarification about our Privacy Policy, complain about our Personal Information processing practices, and/or request to exercise rights in the Personal Information that concerns you.  When you contact us, we might need to make an appointment with you, where necessary, to better understand the nature of your question or clarify your request, such as requests for access, amendment/correction, or deletion of Personal Data.  During this process, we must verify your identity to ensure that the request is made by you, or by another person who is authorized to make a request on your behalf, such as a legal guardian.

 

To contact the supervisory authority:

To contact us: 

www.ico.org.uk

information_governance@optum.com

 

The Information Commissioner

Wycliffe House

Water Lane

Wilmslow

Cheshire SK9 5AF

United Kingdom

 

 

 

Optum Health & Technology Limited

Data Protection Officer

Information Governance

10th Floor

5 Merchant Square

Paddington

London W2 1AS

United Kingdom

 

 

Effective Date & Communicating Changes

 

The Effective Date of this Privacy Policy is 15 May 2018.  From time to time, we may update this Privacy Policy to reflect changes to our information practices. If we make changes to this Privacy Policy, they will be reflected in an updated Privacy Policy that will be posted on the Website, and all changes will be effective upon such posting or upon any later date specified by us in writing.  We encourage you to periodically review this page for the latest information on our privacy practices.  You can determine when this Privacy Policy was last revised by referring to the "Effective Date" above. By continuing to use the Website or any services following the effective date of any updated Privacy Policy, you are agreeing to be bound by the terms and conditions of such updated Privacy Policy.

 

 

 

OneSmallStep Cookie Policy

 

Our website uses cookies. A “cookie” is a small file on your computer which may store information about your visit. For example, cookies help us recognize you as a prior site visitor, to enable website functionality, or to improve our website for your benefit.

 

By using our website you accept the use of cookies in accordance with this Cookie Policy. If you do not accept the use of cookies, please disable them by changing your browser settings so that cookies cannot be placed. If you disable cookies, you may not be able to use some of the functionality of our website.

 

We may allow third party service providers to use cookies or similar technologies. We do not control these third party technologies and their use is governed by the privacy policies of third parties using such technologies. You should check the relevant third party website(s) for more information about these cookies or similar technologies, and whether and how you may opt out of receiving them.

 

Information collected by cookies or similar technologies will be transmitted and stored on servers located in other countries, such as the United States of America.

 

Session Cookies

 

These cookies allow your browser to identify itself to our servers for the duration of your session with the website. We use this information to serve you the correct information from the site, and to submit form data to the correct server on our network.

 

COOKIE

NAME

PURPOSE

EXPIRATION

agft

AngelFish

Analyze user activity

End of session

__utmc

Google Analytics

 Not used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit.

End of browser session

 

Persistent Cookies

 

These cookies allow your browser to identify itself to our servers for a certain period or until you clear the cookies in your browser. This information is used to remember your preferences, displaying content correctly on the website.

 

COOKIE

NAME

PURPOSE

EXPIRATION

agfs

AngelFish

Track unique visitors and exit links.

6 months

_ga

Google Analytics

Used to distinguish users.

2 years

_gid

Google Analytics

Used to distinguish users.

24 hours

_gat

Google Analytics

Used to throttle request rate.

1 minute

__utma

Google Analytics

Used to distinguish users and sessions. The cookie is created when the javascript library executes and no existing __utma cookies exists. The cookie is updated every time data is sent to Google Analytics.

2 years from set/update

__utmt

Google Analytics

Used to throttle request rate.

10 minutes

__utmb

Google Analytics

Used to determine new sessions/visits. The cookie is created when the javascript library executes and no existing __utmb cookies exists. The cookie is updated every time data is sent to Google Analytics.

30 mins from set/update

__utmz

Google Analytics

Stores the traffic source or campaign that explains how the user reached your site. The cookie is created when the javascript library executes and is updated every time data is sent to Google Analytics.

6 months from set/update

__utmv

Google Analytics

Used to store visitor-level custom variable data. This cookie is created when a developer uses the _setCustomVar method with a visitor level custom variable. This cookie was also used for the deprecated _setVar method. The cookie is updated every time data is sent to Google Analytics.

2 years from set/update

 

Analytics, Social, and Advertising Cookies

 

Analytics cookies collect information on how visitors use our website and help us manage website preferences. We use this information to improve our website experience and to customize the website.

 

We use Google Analytics to collect anonymous usage statistics for our website, and use this data to make improvements to site content and design.  A full description of Google practices and how to control cookies can be found here.  https://policies.google.com/privacy?hl=en&gl=uk

 

 

COOKIE

NAME

PURPOSE

EXPIRATION

agfs

AngelFish

Track unique visitors and exit links.

6 months

agft

AngelFish

Analyze user activity

End of session

_ga

Google Analytics

Used to distinguish users.

2 years

_gid

Google Analytics

Used to distinguish users.

24 hours

_gat

Google Analytics

Used to throttle request rate.

1 minute

__utma

Google Analytics

Used to distinguish users and sessions. The cookie is created when the javascript library executes and no existing __utma cookies exists. The cookie is updated every time data is sent to Google Analytics.

2 years from set/update

__utmt

Google Analytics

Used to throttle request rate.

10 minutes

__utmb

Google Analytics

Used to determine new sessions/visits. The cookie is created when the javascript library executes and no existing __utmb cookies exists. The cookie is updated every time data is sent to Google Analytics.

30 mins from set/update

__utmc

Google Analytics

 Not used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit.

End of browser session

__utmz

Google Analytics

Stores the traffic source or campaign that explains how the user reached your site. The cookie is created when the javascript library executes and is updated every time data is sent to Google Analytics.

6 months from set/update

__utmv

Google Analytics

Used to store visitor-level custom variable data. This cookie is created when a developer uses the _setCustomVar method with a visitor level custom variable. This cookie was also used for the deprecated _setVar method. The cookie is updated every time data is sent to Google Analytics.

2 years from set/update

 

How to delete cookies through your browser

 

You can also control and delete cookies through your browser. All browsers are different; however, instructions are usually located within the “Help”, “Tools”, or “Edit” menu. Disabling a cookie or category of cookies does not delete the cookie from your browser. To delete cookies, you need to do so from within your browser settings.

 

Web Logs

In conjunction with the gathering of data through cookies and in order to determine errors, Web servers may log records such as your device type, operating system type, device advertising identifier, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. The Web server logs also may record the address of the Web page that referred you to our Website, the IP address (and associated city and state or province for the IP address) of the device you use to connect to the Internet, and data about your interaction with the OSS Website, such as which pages you visit.

 

Additional Technologies

Apart from our OSS printed material, health & wellness content, and information regarding counseling sessions, the OSS website might include third-party social media features, such as the Facebook button. These features may collect your Internet Protocol address, which page you are visiting on the OSS website, and may set a cookie to enable the feature to function properly.