Intelligent Workforce Solution (“IWS”)

Overview

Your employer (“we” or “us”) has implemented a tasking solution, Intelligent Workforce Solution (“IWS” or the “system”), that uses location data and location-powered scheduling algorithms to optimise resources and workflow and to provide information about the status of tasks, likely start and completion times and the causes of any delays. IWS enables us to optimise our internal processes so we can meet our patient care and performance goals.

You will be given access to a pool of smartphones (“Devices”) for you to use when doing your work. You must keep the Device safe and charged and carry it with you for the duration of your shift in accordance with our equipment policy in the Employee Handbook.

We have set out below details of what types of personal data we collect when using IWS, what it is used for and how long it is kept.  We also describe the legal basis for collecting the data, who it is shared with and what your rights are.

Personal data we collect and how it is collected

  1. Information you provide directly

In the commissioning phase of IWS we may ask you to provide information:

  • By which you may be personally identified, such as name, email address and telephone number (“personal data”).
  • That is about you but individually does not identify you.

These data and their uses are outlined below:

Personal data collectedRetention PeriodBusiness use
Name (first and last)3 yearsTo allow system users to create, track and review tasks by name
Phone number/extension3 yearsTo allow system users to communicate with each other
Email address/Username*3 yearsTo allow users to access the system and communicate with each other
User ID3 yearsTo allow the system to identify unique users
Default location3 yearsTo set controls for regions in which task handlers can operate
Skillset3 yearsTo enable tasks to be given to task handlers with relevant skills
Permissions3 yearsTo control access privileges in the system
Role3 yearsTo enable tasks to be assigned to the correct staff group
Shift times3 yearsTo plan for and optimise availability of staff to complete tasks

Table 1: Personal data we collect directly from you. *Authentication data required for you to access the system (normally email and password) will be kept for as long as you need access.

Additionally, we may collect:

  • Information when you report a problem with the system.
  • Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.

2. Information we collect through automatic data collection technologies  

When you use the system, it uses technology to automatically collect the following information:

Personal data collectedRetention PeriodBusiness use
Location data
Location (within 1000m of premises)IndefinitelyTo establish if user is in the vicinity of the premises
Location (within 400m of premises)Indefinitely  To establish user’s likely entrance to premises
On-site locationIndefinitely  To determine arrival/departure/dwell times for optimisation and analytics
Sensor data (accelerometer, gyroscope, magnetometer, pressure gauge)IndefinitelyTo update signal maps used for location estimation
Wi-Fi scan dataIndefinitelyTo update signal maps used for location estimation and to estimate location
BLE scan dataIndefinitelyTo estimate location
GPS dataIndefinitelyTo estimate location outside to determine task response/ completion times
Historical locations (not linked to task)IndefinitelyTo monitor app efficiency
Semantic/physical/signal mapsIndefinitelyTo estimate location
   
Task handler data**
Task-handler status (ready, on task, on emergency response, on ad hoc request, on break, in meeting, in/out of range, unavailable)3 yearsTo allow system to identify suitable task handler and to allow users to track task-handler status
Historical locations (linked to tasks)3 yearsTo optimise task allocation using recent location data
Any other data characterised as customer staff data3 yearsTo provide additional information about the task handler or other staff
   
Tasking data**
Task type3 yearsTo define tasks for users (eg patient move or blood move)
Task details3 yearsTo identify specifics about task type
Task priority3 yearsTo allow tasks to be prioritised
Task status (unassigned, assignment in progress, in progress, paused, cancelled, pending approval, pending verification, completed)3 yearsTo allow portal users to track status of task
Estimated time of completion3 yearsTo allow portal user to estimate completion time
Actual time of completion3 yearsTo allow system users to track time taken to complete tasks
Response time3 yearsTo allow customers to manage service level compliance
Breach time3 yearsTo allow customers to manage service level compliance
Time stamps for all task activities3 yearsTo allow the system to track the progress of tasks by time
Notes (excluding patient notes)3 yearsTo allow system users to add additional instructions for a task
Free text fields for task information3 yearsTo allow system users to add additional information about a task
Task waypoints3 yearsTo inform the task handler about locations associated with task
Task linkage information3 yearsTo allow users to identify tasks that are linked together
Task ID3 yearsTo allow the system to identify a task by reference ID
Task skillset3 yearsTo identify skillsets required for a given task

Table 2: Personal information we collect automatically through your use of the system. ** Task handler data and tasking data are only visible to customer for 12 months.

Location information will include GPS data and sensor data from the Device (from the accelerometer, gyroscope, magnetometer, Wi-Fi, BLE beacon or pressure information). The IWS system will start to acknowledge GPS signals when the Device is within 1km of the premises and this frequency will increase the nearer you get.  Once you enter the premises, the system will then use a combination of the sensor data and the building plan to work out your location which is then linked to room references inside the premises.

You should note that the Device will continue to determine your approximate location until you log out of your account. We recommend that you log off the Device if you leave the premises or when you have finished your shift.

Tasking information will include login/shift times, user state, task state and lapse times.  This information is collected when you login to the system and when you are communicating, via the Device, with the person who is assigning tasks.  For example, if you accept a task, IWS will track the status of the task and, among other things, how long it takes to be completed.  At the end of your shift, when you log out, IWS will record when this happens.  

Use of your personal data

We will use your personal data, during the commissioning of IWS, to make sure that the system is set up and functions properly.  After commissioning, IWS will use that information, together with the location information it collects when you are using the system, to determine which tasks should be allocated to you.  This process is automated but takes into account your work and skills group, location and availability.  The system is designed to ensure that tasks are assigned to the right person, in the right place at the right time to improve productivity and enable better healthcare outcomes. 

We will also use information collected by IWS to review task-completion data and to run reports.  This provides an insight in work and task-completion patterns and allows us to optimise our internal processes. Reports will show aggregated data across a work group or team, or specific data relating to particular tasks or individuals.  However, as IWS is a workforce efficiency tool, it is not designed specifically to manage individual performance and only in exceptional cases would it be used for that purpose.

Legal basis for processing

We process the personal data collected by the Device (i) to perform a task carried out in the public interest and (ii) in order to perform our contract of employment with you.

Sharing of your personal data

We will share your personal data with the supplier of IWS, Navenio Limited, who acts as a data processor on our behalf.  We may also disclose your personal data to others where necessary in order to comply with any legal or regulatory obligations.

If you are located in the UK, your personal data will not be transferred outside the United Kingdom and the European Economic Area.  If you are located elsewhere, your personal data will be securely stored in accordance with arrangements made with Navenio Limited.

Data Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and where they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Retention period

Unless we are under a legal obligation to retain information for a longer period, we will keep your personal data for no longer than is necessary for the purposes set out above under “Legal basis for processing”.  The normal retention periods are as detailed in tables 1 and 2.

If we change the way we process your personal information or how long we need to keep it, we will notify you accordingly.

At the end of the retention period your personal data will either be deleted or anonymised.

Your rights

You are entitled to make a request to us to get access to your personal data.

If your personal data is inaccurate or misleading, you are entitled to request that we rectify the information.

Under certain conditions, you have the right (i) to request us to erase or restrict access to your personal data or (ii) to object to the processing.

You may also have the right to data portability and, where you do, we will provide you with your data in a suitable format at your request.

If you have any further questions about why and how we process your personal data or if you wish to exercise any of the rights described above, in the first instance please contact our Data Protection Officer.

If you have any concerns or complaints about the way your personal data is being handled, you may also contact the Information Commissioner’s Office online or by calling 0303 123 1113.