Draft. This statement is awaiting review by our Data Protection Officer and legal advisers. Items marked like this are still to be confirmed.

In short

Who we are

MySpine.Health is provided by [legal entity name, company number and registered address] (“we”, “us”). We are the controller of the personal data described in this statement.

Questions about your data, or about this statement: [email protected].

What we collect

If you decide not to join, you can tell us why. That answer is anonymous: we keep only your employer’s name, the reasons you picked and the date.

We use one essential cookie to keep you signed in. We don’t use advertising or tracking cookies.

Why we use it

Our legal basis (to be confirmed by our DPO): for your health information, your explicit consent (UK GDPR Article 9(2)(a)) and, where our clinicians are caring for you, the provision of health care (Article 9(2)(h)).

Who sees what

Your employer (HR, managers and others)Only totals and summaries about groups of at least 10 people. Smaller groups are combined or hidden. Never your name or your answers, and not whether you have joined.
Your employer’s Occupational Health teamOnly if you say yes. They can see your name, site and department, your questionnaire, your check-ins and pain trend, your back problems, follow-ups and days off, exercises you’ve done, and whether you’ve been referred for care. They may contact you about your back. They never see your safety and risk answers or anything a clinician records. If you stop sharing, they lose access to all of it straight away, including anything from before.
The MySpine.Health clinical teamRegistered physiotherapists and doctors, when you ask for help or your answers suggest you need it.
Our service providersGoogle Cloud stores the data, in London. Cloudflare delivers the app’s pages and protects connections. An email provider sends your sign-in codes. They act only on our instructions.

We never sell your data or use it for advertising.

Where it’s kept, and for how long

Your data is stored and processed in the UK (London), and encrypted in transit and at rest.

We keep it while you have an account, and for [retention period] after you last use the app. If you delete your account, your data is deleted straight away (copies in our encrypted backups are overwritten within [backup period]). We keep only a record that a deletion happened. If you leave your employer, sharing with that employer ends.

Your rights

Changes to this statement

If we make important changes, we’ll tell you in the app before they apply.