Rotamap Software as a Service Privacy Notice
Revision F, 10 October 2019
This privacy notice pertains to Rotamap's software as a service (SAAS) clinical staff rostering services, CLWRota, Medirota and Central Reporting.
This notice explains how personal data is used in the services for both clinicians, rota administrators and those who deal with personnel and rota-related data between departments. This document provides 'privacy information' pursuant to the General Data Protection Regulation (GDPR) and aims to follow the guidelines concerning privacy information and privacy notices set out by the United Kingdom's Information Commissioner's Office (ICO).
To correspond with the Rotamap team concerning this privacy notice and the privacy information contained in it or any other requests or enquiries concerning personal data please contact Rotamap at firstname.lastname@example.org, or at the contact address provided at the end of this document.
Rotamap provide three software as a service (SAAS) services: CLWRota, Medirota and Central Reporting. There is more information about each of these services available at www.rotamap.net/clwrota, www.rotamap.net/medirota and www.rotamap.net/central-reporting. CLWRota is a specialist rota management system for anaesthetic departments. Medirota is a rota management system for all other clinical staff groups. Central Reporting reports on department rotas within a Trust.
Rotamap's SAAS services are provided over the internet between our servers based in our data centre racks in central London and Slough to standard web browsers on devices such as desktop computers, tablets and smart phones and native iOS and Android apps. Communications between client devices and the data centre are encrypted using HTTPS encryption and authentication is required to access resources on the services.
Credentialled access to the services are enforced through the use and expiration of authentication tokens and/or cookies. Passwords are stored in hashed format in our databases.
Rotamap's servers are located in server racks maintained by Rotamap staff in ISO27001, ISO5001 accredited facilities, and our provider has PCI-DSS L1SP Physical accreditation. Physical access to our servers requires multiple levels of authentication. Database backups are public/private key encrypted. Network access to servers between data centers or from the internet is via multiple levels of firewalls and performed over either HTTPS or SSH encrypted channels.
Live databases and encrypted backups are only located in London, UK and Slough, UK.
Rotamap aims to take a ‘data protection by design and default’ approach as recommended by the Information Commissioner's Office.
Relationships with organisations and individuals
Rotamap's SAAS services are taken up at an organisational level, for example by NHS Trusts, hospitals or departments. A group of individuals are appointed by the organisation to administer the rota, which requires certain personal information to be held for both the administrators and rostered staff members. The organisation acts as 'data controller' and determines whose information is used in the system. Each rota is contained within its own discrete database on our servers.
Rotamap's SAAS services store this personal information and process it using computer code to provide rota management services to the organisation, the rostered staff, and other parties given access to the rota information by the organisation, for example the organisation's theatre management team. Rotamap's staff may also access personal or rota information to provide training or assistance to the administrative team when called upon to do so by the organisation or to investigate software bugs. Rotamap acts as 'data processor' to the organisation and we have a legal requirement to maintain records of the personal data we hold and how it is processed.
Administrators and rostered staff members therefore can approach both the organisation, as data controller, or Rotamap, as data processor, for further information about their rights, the type and use of personal information or access requests.
Rotamap's services are not to be used for patient information.
Personal data held and processed in our systems
Administrative staff are identified by their name, email address and role in the system. Administrative actions are logged against the user who made those actions.
Rostered staff are identified primarily by their name, email address and role in the system. Ancillary information may include mobile phone numbers, home telephone number, bleep number, GMC number and ESR assignment number for linking with external payroll systems, training module assignments and optional short notes about the individual, for example sub-specialty skill sets for rostering purposes. The individual's start date is recorded, as is their end date if known.
In order to roster staff different types of planning configuration are typically made to set the recurrent planned work patterns of each individual. The amount of anticipated work for a period, such as a year, may be also be set. Individual profiles may similarly be associated with rules to determine their non-availability.
For active rotas staff may be assigned to an activity based on the planned configuration or through direct assignment by an administrator, thereby associating the staff member with the qualities of that assignment which may include the values of that assignment in, for example, PA and hour units amongst others, the name of the session, and any notes and markers.
Calculations are performed through the system software to process the above information to determine whether a staff member may be assignable to an activity or not. Similarly calculations are performed to determine what assignments have been made historically for reporting purposes, including, for example, determining if a staff member may be assigned to another annualised session for the year.
Administrators can view rotas, as can participating staff members whose activities are rostered in the system and whose term of service has not expired. The organisation may also provide read-only views to other parties to allow, for example, clinic management teams to learn which clinicians are due to work in a particular week.
The systems include leave management and messaging facilities. The first stores leave requests, their associated information and decision notes together with the impact of that leave on the rota. The second allows administrators to send messages to staff members which are then stored in the system, which may also be sent as alerts via channels such as email, push or text message depending on the staff member's settings and/or the urgency of the communication. The organisation may configure the messaging system to alert other parties, such as theatre or clinic team members, to events such as a surgeon's approved or cancelled leave.
Information stored in the system is retained for the life of Rotamap's contract with the organisation unless otherwise directed by the organisation. This is to ensure that historical records such as the nature and timing of particular events can be retrieved.
Information in the system is accessible to administrators and those who deal with personnel and rota-related data for reporting purposes. Individuals whose term of service has not expired can also run reports on their own activity and view their profiles. Application Programming Interface (API) access to system data can be enabled by the department to provide programmatic access to the data useful for integration into other services.
Further use of data
Apart from the uses noted above personal data is also streamed between servers to ensure that services can be maintained in the case of a server failure, and backups are made twice a day of each database and then GPG private/public key encrypted before being stored on other servers and at our office over encrypted ssh channels.
To fix a specific software fault or issue a department database may be copied and psuedo-anonymised in a secure environment for investigation. For all other purposes a department database may be copied and used in an environment controlled by Rotamap staff only after being fully anonymised to remove all personal details.
Data from the databases are used to provide aggregate data with no personal attributes for use in department analysis reports and to provide data sets for, for example, academic articles.
Messaging services may be provided through third parties whose GDPR compliance has been checked. Message content is not stored by the providers.
Our native Android and iOS apps use Google Firebase Cloud Messaging, Analytics, and Crashlytics. These services collect a unique token identifier, which Cloud Messaging uses to deliver push messages, and which Crashlytics and Analytics use to collect anonymised information on how our apps are used as well as crash reports. All information collected is only used to provide our services and to improve how our apps work.
Privacy and GDPR information for Firebase can be found on their Data Processing and Security Terms. Google will delete a token within 180 days, tokens remain active until:
- The app is restored on a new device
- The user uninstalls/reinstalls the app
- The user clears the app data
Personal data is not mixed with information from other sources, and no personal information is provided by Rotamap to any other third party.
Personal data rights
The GDPR sets out various important rights relating to personal data which are summarised on the ICO's website. These rights include the right to be informed, right of access, right of rectification and several others.
Individuals whose personal data are stored in Rotamap's systems who wish to exercise one of these rights can contract the organisation (as controller) or Rotamap (as processor) to do so. We are required to respond to requests in 30 days. Please note that communication regarding your case will be dealt with through the organisation's data protection officer. Answers to questions concerning personal information may be most effectively answered by the administrative team in charge of the rota containing that information.
You can make an access request, or exercise one of your rights, by emailing email@example.com or writing to:
The Data Protection Officer
3 Tottenham Street
London W1T 2AF