Privacy Policy

Government of Barbados Ministry of Health and Wellness; BENApp – Privacy Policy

Effective as of February 6, 2021

This “Privacy Policy” explains how the Barbados Ministry of Health and Wellness (the “Ministry”) collects, uses, discloses and otherwise processes end users’ data in connection with the mobile application “BENApp”. The Application Provider for BENApp is the Keyed Systems, LLC. This Privacy Policy also describes the choices available to individuals with respect to data when using BENApp.

About the Ministry and BENApp

BENApp is intended for use to augment traditional contact tracing in response to COVID-19. Contact tracing consists of notifying and monitoring individuals who have been in close contact with someone who is infected with a virus and could potentially infect others. BENApp allows users to store data collected and processed by the App for the purposes of contact tracing locally on the respective user’s mobile device. BENApp can notify users if they have been exposed to a COVID-19-infected individual and provide instructions on how and where to get tested, and do so while preserving anonymity and collecting no PII.

How it Works

Ministry and the Application Provider never collect or process any personally identifiable information from BENApp. Bluetooth random IDs are assigned to each device using BENApp. Each user’s random code changes frequently to further protect their identity. When a BENApp user comes into close contact with another BENApp user, their random codes are exchanged using Bluetooth. Random codes for close contacts are stored in a user’s device for 14 days. No personally identifiable or location information is collected, stored, or exchanged.
If a user tests positive for COVID-19, they may choose to notify other BENApp users who may have had close contact with them. To trigger such notification, a user who tests positive for COVID-19 must enter a valid, 8-digit PIN provided by a Ministry Contact Tracer staff member. This PIN is randomly generated by Ministry and only used to enter a positive diagnosis in BENApp. Once a valid PIN is entered into BENApp, a risk calculation is made using the time, duration, and Bluetooth signal attenuation (proximity indicator) collected by BENApp for each contact event between BENApp users, and other BENApp users who are calculated to have been in close contact with the user who tested positive will be alerted. Users may receive exposure notifications in BENApp to let them know they encountered a possible exposure.

Your Choices

USING THE APP

Using BENApp is completely voluntary, and you may choose to install and uninstall BENApp at any time. BENApp will never collect, track or store your location, GPS information, or personal information. The App is offered for free to Residents and all Visitors to Barbados.

Enabling Exposure Notifications

Enabling exposure notification in BENApp is your choice. You can enable and disable such notification at any time. It must be enabled for BENApp to exchange the random codes with other BENApp users who you come into close contact with, for you to receive exposure notifications, or for you to notify other BENApp users if you test positive for COVID-19 by sharing your random codes through a positive report.

Notifying Other App Users If you Test Positive

If you test positive for COVID-19, you may choose to notify other BENApp users who you have been in close contact with. Providing notification to other BENApp users with whom you have had close contact is completely voluntary. The notification will not disclose your identity or any personally identifying information. To enable such notifications, you will need a valid, 8-digit PIN provided by the Ministry Contact Tracer. This PIN is used to verify your positive diagnosis and prevent false reports. This PIN is not associated with your identity. Once a valid PIN is entered into BENApp and you confirm that you wish to anonymously notify other users you may have encountered, after you confirm, all BENApp users who have enabled their app configuration to receive notifications will receive your Bluetooth random IDs to determine if there has been any close contact with you. Such notifications will NOT include your identity or the date, time, or location of the exposure.

Terminating App Participation

Participation in BENApp may be terminated at any time by deleting or uninstalling BENApp from your device. After BENApp is deleted or uninstalled, your device will no longer generate or exchange Bluetooh random IDs with other users. Any Bluetooth random IDs that were previously shared with other BENApp users will be automatically deleted after 14 days from the date the PIN was generated.

Sharing Of Information

The following event data may be processed and collected in BENApp without the inclusion of any personal information:

Installing BENApp
Enabling and disabling Exposure Notifications
Receiving an Exposure Notification
Submitting a verified PIN
Sharing a positive result
Downloading anonymous tokens for positive users that have chosen to notify others
Deleting the app

We use the above event information to understand how BENApp is being used. This data may be shared with other entities. It may be used in aggregate and anonymous form for statistical or scientific research purposes. This information will not include any personal or location information nor can it be used to identify any BENApp user.

Opting Out of Push Notifications

If you opt-in to receive push notifications within BENApp, it may send push notifications or alerts to your mobile device from time to time. You can deactivate push notifications and alerts at any time by deleting BENApp, changing your device settings, or changing the push notification settings within BENApp.

Age Requirements

BENApp is not intended for children under the age of 14, and we do not knowingly allow a child under 13 to use the App. If you are between the ages of 14 and 17, you can only use BENApp if your parent or legal guardian has reviewed and agreed to the Apps terms on your behalf.

Changes to Our Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes to our Privacy Policy, we will notify you by posting the changes on BENApp or by using the contact information you provide to BENApp. The notification will indicate when such changes will become effective. If you object to a new Privacy Policy, you may terminate participation in BENApp by deleting or uninstalling BENApp.

Contacting Us

If you have any feedback, or any questions, comments, or concerns relating to this Privacy Policy or our privacy practices, please contact us at our Contact Us page or write to us at the following address:

Ministry of Health and Wellness

Frank Walcott Building, Culloden Road
St. Michael
Barbados, W.I.

Email: covid19app@health.gov.bb
Phone: +1 (246) 536-3800