MyPath KY App Privacy Policy

Last modified: 8/29/24

Introduction

The University of Kentucky ("University," "we,” or “us”) respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes:

·      The types of information we may collect or that you may provide when you download, install, access, or use the MyPath KY Application (the "App").

·      Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect in this App, and other electronic communications sent through or in connection with this App.

This policy DOES NOT apply to information that:

·      We collect offline or on any other University apps or websites, including websites you may access through this App.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, access, or use this App. By downloading, registering with, or using this App, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this App after we revise this policy means you accept those changes, so please check the policy periodically for updates.

Children Under the Age of 18

The App is not intended for children under 18 years of age, and we do not knowingly collect personal information from children under 18. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at c4program@uky.edu.

Information We Collect and How We Collect It

We collect information from and about users of our App:

·      Directly from you when you provide it to us via surveys or otherwise via the App.

·      Automatically when you use the App.

Information You Provide to Us

When you download, register with, or use this App, we will ask for your permission to share your de-identified (anonymous) App usage data and general patient demographic information. The purpose of the App is to conduct a study to ultimately improve timely access to community-focused, patient-centered, and high-quality cancer care by providing a digital patient assessment and service referral system.  When using the App, you may be asked to provide information:

·      By which you may be personally identified, such as name, postal address, email address, telephone number, social security number, or ANY OTHER INFORMATION THE APP COLLECTS THAT IS DEFINED AS PERSONAL OR PERSONALLY IDENTIFIABLE INFORMATION UNDER AN APPLICABLE LAW ("personal information").

·      General information about you, the App, your experience with patient navigation services including but not limited to transportation, billing, food, housing, and psychosocial screening and support at your cancer treatment hospital or facility.

This information includes:

·      Information that you provide by responding to the survey questions in the App which are used solely for research purposes.

·      Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.

Information We Collect Through Automatic Data Collection Technologies  

When you download, access, and use the App, it may use technology to automatically collect de-identified and anonymous data, such as:

·      Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the App.

·      Device Information. We may collect information about your mobile device and internet connection, including the device's unique device identifier, IP address, operating system, browser type, mobile network information, and the device's telephone number.

In addition, the App may log your keystroke level data and save them to a secure data center. These data show the amounts and patterns of the system usage.  Examples of system usage metrics may include the following: navigator and patent logins, user-generated messages, responses to psychosocial assessment, referral status updates, patient navigation caseloads, and closed referral loops.  For the anonymous longitudinal sample, your data will be transferred to our team from the App server with an anonymous ID number and no identifying information.

If you do not want us to collect this information, do not download the App or delete it from your device. For more information, see  Your Choices About Our Collection, Use, and Disclosure of Your Information below.

 

How We Use Your Information and Who Will See the Information That You Give?

All data gathered via the App will be used solely for research purposes. When we write about or share the results from the study, we will write about the combined information. We will keep your name and other identifying information private.

We will make every effort to prevent anyone who is not on the University’s research team from knowing that you gave us information, or what that information is. Regardless of how you complete surveys (online or paper), any documents that have your name on them will be stored separately. All study documents, including your surveys, will be stored securely, either in locked filing cabinets by the study team or on secure electronic databases accessible only to the study team. You will not put your name on your surveys and your name will be kept separate from the information you provide. To confirm your study enrollment, a limited amount of information will also be entered into Oncore®, a restricted- access database maintained on secure servers at the University of Kentucky. Computer-based files will only be made available to personnel involved in the study with access privileges and passwords. Your responses will be kept confidential to the extent permitted by law.

We will share limited information about you with Virginia Commonwealth University to evaluate this project together with projects at other cancer centers. Before sharing your information, all your personally identifiable information will be removed.

In some cases, the law may require or permit us to share your information with authorities, such as child or adult protective services, if you report information about a child or elder being abused, or to authorities or a mental health professional if you pose a danger to yourself or someone else (e.g., suicidal thoughts).

To ensure the study is conducted properly, our officials may look at or copy pertinent portions of records that identify you. All study records will be maintained for a minimum of six (6) years after study closure and destroyed per our policy.

 

Disclosure of Your Information

With your consent, we may disclose de-identified (anonymous) App usage data and general patient demographic information with our study evaluation team.

As previously noted, we will share limited information about you with Virginia Commonwealth University to evaluate this project together with projects at other cancer centers. Before sharing your information all your personally identifiable information will be removed.

In some cases, the law may require or permit us to share your information with authorities, such as child or adult protective services, if you report information about a child or elder being abused, or to authorities or a mental health professional if you pose a danger to yourself or someone else (e.g., suicidal thoughts).

 

Your Choices About Our Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the personal information you provide to us.  When you download the App for the first time, a set up screen will prompt you to give permission to share your data (or decline). For the anonymous longitudinal sample, your information will be transferred to our team from the app server with an anonymous ID number and no identifying information.

You can choose to leave the study at any time. You will not be treated differently if you decide to stop taking part in the study. If you choose to leave the study early, data collected until that point will remain in the study database and may not be removed.

You may have additional personal information rights and choices under Kentucky law. Please see Your State Privacy Rights for more information.

Accessing and Correcting Your Personal Information

You can review and change your personal information by logging into the App and visiting your account profile page.

You may also send us an email at c4program@uky.edu  to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Residents in certain states, such as California, may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

Your State Privacy Rights

Kentucky’s consumer privacy laws may provide t additional rights regarding our use of personal information.  The exact scope of these rights may vary over time. To exercise any of these rights (to the extent they may exist), please submit a detailed written request to c4program@uky.edu.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

Your responses will be entered into REDCap, a secure, web-based program to capture and store data at the University of Kentucky. REDCap requires HTTPS login access. Hypertext Transfer Protocol Secure (HTTPS) is a combination of the Hypertext Transfer Protocol with the SSL/TLS protocol to provide encryption and secure identification of the server. HTTPS connections are used for payment transactions on the Internet and for sensitive transactions in corporate information systems.  Please be aware, while we make every effort to safeguard your data once received on servers via REDCap, given the nature of online surveys, as with anything involving the Internet, we can never guarantee the confidentiality of the data while it is sent to the server. 

You may decline to answer any questions to which you do not wish to respond or questions that make you feel uncomfortable.

Data for all participants will be kept strictly confidential, except as mandated by law.  All research files will be kept on secure, password protected servers.  All electronic data will be stored on secure servers behind firewalls.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Changes to Our Privacy Policy

We may update our privacy policy from time to time. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the App.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address and/or phone number for you and for periodically visiting this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

c4program@uky.edu