1. Introduction
At AfterSurg Ltd (“we”, “our”, “us”), we are committed to protecting your privacy and handling your personal data responsibly. This Privacy Policy explains how we collect, use, store, and share your data when you use our medical application (“the App”) (referred to herein as “AfterSurg” for consistency). It also describes your rights in relation to your data under applicable UK laws, including the General Data Protection Regulation (GDPR) under the Data Protection Act 2018, and relevant medical device regulations.
2. Data We Collect
When you use the App, you will be asked to grant access to your health data services from your operating system. Specifically, we will collect information about your activity levels over two periods:
- Pre-operative data: Activity data from up to three months before a specified date (coinciding with your operation or medical procedure).
- Post-operative data: Activity data for up to six months after the specified date (coinciding with your operation or medical procedure).
In accordance with data minimisation principles, we only collect data that is strictly necessary to provide you with a personalised recovery journey and to support ongoing clinical research.
3. How We Use Your Data
We use the collected data for the following purposes:
- Personalised Recovery Journey: To generate and deliver a tailored post-operative recovery plan based on your activity levels and the type of procedure you have had.
- Medical Research: An anonymised form of your data, which contains no personally identifiable information, will be stored securely and used to contribute to ongoing clinical research, improve the App’s ability to predict recovery patterns for future patients, and collaborate with carefully selected third parties such as universities, charities, and commercial organisations.
4. Legal Basis for Data Processing
We process your data based on your explicit consent, which you provide when granting access to your health data services from your operating system. You have the right to withdraw your consent at any time as described in Section 8.
5. Data Storage and Security
We are committed to ensuring your data is handled securely:
- Anonymisation: Personal identifiers are removed to create anonymised data for research and App improvement purposes.
- Secure Database: All data is stored in a secure database that complies with industry standards and requirements, ensuring the highest levels of data protection.
- Data Retention: Anonymised data may be retained indefinitely for research purposes; this data is key to ongoing clinical research.
6. Sharing Your Data
We do not sell or share your personal data with third parties for marketing purposes. Anonymised data may be shared with:
- Accredited research organisations for medical research.
- Internal teams for improving the App’s features and algorithms.
- Carefully selected third parties, including universities, charities, and commercial organisations.
- Your identified surgeon, physician, or other healthcare professional, in anonymised form, to help them monitor their practice and maintain high standards of care.
7. Your Rights
Under UK GDPR, you have the following rights:
- Access: Request general information about how your anonymised data is processed.
- Correction: Not applicable, as no identifiable data is collected that can be corrected. However, should any identifiable data ever be collected or processed, you will have the right to request corrections.
- Restriction: Request the cessation of further data collection or processing of anonymised data.
- Objection: Object to processing based on legitimate interests, which may include medical research or App improvement activities.
- Data Portability: Not applicable, as no identifiable data is collected. Should this change in the future, you will be entitled to receive your data in a portable format in accordance with applicable law.
- Withdraw Consent: You may withdraw your consent for data collection and processing at any time by following the steps outlined in Section 8.
- Erasure: Please note that you do not have the right to request the deletion of data used for medical research purposes under the UK Data Protection Act (2018), as erasure may seriously impair the ability to archive data and impede the achievement of scientific research objectives.
8. How to Stop Data Collection
If you wish to stop the collection and use of your data, please follow these steps:
- Revoke the App’s access to your health data services by navigating to your device’s settings, selecting the privacy or data permissions section, and removing AfterSurg’s access.
- Contact us at support@aftersurg.com with your request to cease further data collection and processing.
- We will confirm receipt of your request and provide any further instructions if necessary.
Please note that stopping data collection will not affect any recovery plan or guidance you have already received through the App.
9. Contact Information
If you have any questions about this Privacy Policy or how your data is handled, please contact us:
10. Updates to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in regulations or our practices. Any significant changes will be communicated to you through the App. Your continued use of the App after any updates constitutes acceptance of the revised policy.
11. Complaints
If you believe your data has been handled improperly, you have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO):
Website: ico.org.uk
Phone: 0303 123 1113
12. Acceptance of Terms
By clicking “I Agree” or using the Application, you confirm that you have read, understood, and agreed to the terms of this Privacy Policy. Your use of the Application also constitutes your consent for AfterSurg Ltd to access your health data services as described herein. If you do not accept the terms of this Privacy Policy, you must refrain from using the Application.