Barbados and countries around the world are currently battling the COVID-19 pandemic. In Barbados, this has resulted in the Government of Barbados declaring a Public Health Emergency.
The BIMSafe mobile user application (the “App”) is offered by the Ministry of Health and Wellness, working with the Ministry of Innovation, Science and Smart Technology and other key partners as part of Barbados’ strategy for effectively managing the impact of COVID-19 on our society.
Table of Contents
- What does the BIMSafe App do?
- What information are we collecting from you?
- What do we do with it?
- Who will we share your information with?
- What is our legal basis for using your information?
- Will your information be secure?
- How long will the information be kept for?
- What are your privacy rights?
- What about updates to this policy?
- Who do you contact about this policy?
The App supports Barbados’ national public health emergency response during the COVID-19 crisis by allowing visitors and residents that are required to self-report health symptoms and/or required to quarantine to do so safely and in compliance with policies/protocols of Barbados Ministry of Health and Wellness. In the event that you are concerned that you might have contracted COVID-19, the App will help you locate relevant health centres and other resources that you may access for further information, testing and/or treatment while in Barbados.
The App is also an informational resource providing you with up-to-date travel protocols, news, statistics, and other relevant health, tourism, customs, and immigration-related information to aid you in navigating Barbados safely.
Your privacy is important, and information protection is a core pillar of our response program. When you install the application no user registration or password is necessary. Identifiers provided to you by other official Government services are entered into this application… allowing the application to communicate other information about you to existing secure systems.
In the event you are required to report symptoms, we will collect information about whether you have not tracked symptoms on required schedules, and if the symptoms you entered should be cause for alert. Symptoms you enter are not collected or stored.
In the event you are required to quarantine, we collect the location you will quarantine at. You may be provided a wearable device that interacts with this Application. The GPS location of your phone, and whether the wearable device is nearby is recorded as in or out of range of the quarantine location.
If events relative to symptoms recording or quarantine require follow-up, enforcement, or healthcare attention, case information may be generated outside the application with relevant government programs.
If you utilise the symptom-monitoring features of the App, we will collect information about the symptoms you are experiencing, the time of day you are experiencing them.
If you utilise the wrist-band features of the App, we will collect information about the proximity of the wrist-band to the App.
This information will not be uploaded to the servers of the Ministry of Health and Wellness of the Government of Barbados or otherwise transferred from the App unless you meet certain defined criteria.
Any information you share via the App with the Ministry of Health and Wellness, Government of Barbados, will not be shared with other Government agencies unless they are part of the overall strategy for responding to the COVID-19 Public Health Emergency.
The complete list of those who have access to this information are:
- The BIMSafe App development Team, which includes both Keyed Systems and directly contracted local developers.
- Reason: System support.
- The Barbados COVID19 Survelance Unit — National Monitoring Team.
- Reason: In the case of quarantine violation or symptoms alert, Travel Code is available for follow-up.
- BIMSafe App onboarding teams.
- Reason: Can scan the Gateway Code presented by the App.
Information collected is not shared with any other party.
We will only use your personal data where we have a lawful basis for doing so. In every case, the legal ground will be one of the following:
- Where you give us your consent. You can withdraw your consent at any time by contacting us via our contact details below;
- To protect your vital interests, where the information you self-report indicates a risk to your own health such that you may not be able to expressly consent to us processing information that may be useful to save your life;
- For our legitimate interest, where it is necessary for us to understand how users like you use the App, and to improve the App;
- To comply with our legal or regulatory obligations.
Information you provide will be held in accordance with the standards outlined in the Barbados Data Protection Act, 2019-29. Any personal information you share with the Ministry of Health and Wellness, Government of Barbados, will be held securely in compliance with the Government’s standards. We will ensure that appropriate methods are utilised to safeguard your personal data from unauthorised access.
We will not keep personal data longer than is required for the App to function effectively. We will keep most personal data for the entire time you use the App. In some cases, we may retain personal information for longer if the law requires us to do so.
In deciding how long to keep your personal data, we consider the reasons why we hold it, its sensitivity, how long the law requires us to keep it, and the risks associated with retaining it.
The health information we collect from you when you self-report will not be kept. If upon self-reporting the information you share with the App meets certain predefined criteria, that data may be transferred to the Ministry of Health and Wellness where it may be processed for up to 60 days.
You have a number of rights under the Data Protection Act, 2019-29 and the Electronic Transactions Act Cap 308B of Barbados. Except as limited under applicable law, these rights include:
- Right of access – the right to be informed of, and request access to, the personal data we process about you;
- Right to rectification – the right to request us to amend or update your personal data where it is inaccurate or incomplete;
- Right to erasure – the right to request us to delete your personal data;
- Right to restrict – the right to request us to temporarily or permanently stop processing all or some of your personal data;
- Right to object –
- the right, at any time, to object to us processing your personal data on grounds that should we continue to do so, it will likely cause you damage or distress;
- the right to object to your personal data being processed for direct marketing purposes;
- Right to data portability – the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service;
- Right not to be subject to automated decision-making – the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect;
- Right not to have your information transferred to any third party without your consent; and
- Right to withdraw your consent at any time in respect of the processing of your personal data.
In order to exercise any of your rights, requests should be made to firstname.lastname@example.org.
We will respond to any legitimate requests within one month. If your request is unfounded, repetitive or excessive, or if we are not in a position to identify you, we are entitled to refuse to act on your request.
This policy was last updated on November 30, 2020.
From time to time we may make changes to this policy to reflect changes in how the App functions. If these changes significantly impact how we will process your personal data we will alert you via email, if you have provided one to us.
At no point will your rights be less than they are now.
Ministry of Health and Wellness,
Frank Walcott Building,
Phone: +1 (246) 536-3800