Record of processing activities

Who we are

The processor for all of the below activities is Patient App B.V. Koppelland 3, 1391EV Abcoude, KvK-number: 71943765. The processor is represented by Thomas Goijarts, Koppelland 3, Abcoude, The Netherlands, who can be contacted at The processing activities described below are for users of the Patient App B.V. platform. The Patient App B.V. platform is called Caro.

Purpose of processing

The Caro application collects and processes personal data in order to:

  1. Provide patients with personalized content to guide them, motivate them, and keep them informed throughout a treatment
  2. Track and provide visibility on the progress of a patient through this personalized content
  3. Facilitate healthcare professionals and healthcare-related businesses improving the quality of the service they provide
  4. Invite users to the platform
  5. Continually improve the products that are used for 1, 2, 3, and 4 above

Categories of individuals

Caro collects data about the following classes of individuals:

  1. Patients
  2. Healthcare professionals
  3. Staff of healthcare-related businesses
  4. Caro health employees (when they do support work on the platform)

Categories of personal data

Caro processes the following types of personal data:

  1. Basic identification information - name, phone number, and password - to allow users to sign in to the platform
  2. For patients, metadata about their treatment - for example the treatment date
  3. For patients, patient-supplied and context-derived information to facilitate content personalization, for example a self-reported pain grading
  4. For all users, user-supplied information to facilitate continuous improvement of the Caro health product - for example NPS scores
  5. For all users, an audit log of all activity on the platform

Recipients of personal data

The Caro application stores personal data with ISO27001 and HIPAA compliant cloud providers:

  1. All user data, including personal healthcare data, is stored in databases running on AWS within the EU
  2. Authentication data is stored in AWS Cognito within the EU

The Caro application does not transfer personal healthcare information outside of the EU. Basic personal information about administrators is sent to Intercom to facilitate customer success and support.

Retention of personal data

The Caro application stores all personal data for 9 years after a user is last active, in order to:

  1. Support historical reporting
  2. Maintain an audit log of activity on the platform

Exceptions to this practice are:

  1. When a user exercises the right to be forgotten - in which case all of their personally identifiable data will be removed from the platform within 45 days of the request (when the last backups with their data expire), and their user data will be anonymised
  2. When a customer terminates their contract, and submits a request for their data to be deleted

Security measures

See how we approach security at Caro.