BACK-TRACK Europe Ltd.'s Privacy Policy

GDPR is a significant update to European Privacy law and has required organisations to review their procedures which is why we have produced this updated document. We do not anticipate significant future changes, however, it will occasionally be updated and we would recommend you check it periodically.

We hold very little personal data and can therefore be very specific about what data we hold. As an organisation, we have always taken the privacy of our clients and users [BACK-TRACK device users] very seriously and therefore compliance to the requirements of GDPR is an enhancement to our existing systems.

Information sharing - we shall not divulge any client or user data to any third party other than in accordance with this policy or with the client's express advance written authority.

We have never tracked users via cookies on our website and we store all data on our own dedicated servers located within the EU. We do not register or store the IP addresses of visitors to our website.

Personal Data

As a wearable device provider, we are very conscious of users and employer's concerns about how we store and safeguard the BACK-TRACK user's personal data. Where GDPR laws exist, we have a policy of collecting No Personal Data for BACK-TRACK users. We place this responsibility on the client to provide us with a unique, non-identifiable number that the client only can cross-reference to the user. Alternatively, we will provide a barcode scanner that will scan an ID tag and store the last six digits only. This can also be used by you and your employer to identify you. We collect movement data associated with the unique serial number. Use of the BACK-TRACK app is facilitated by logging in using your unique number and the format for this (including passwords) will be communicated by your employer). This functionality allows use of the BACK-TRACK system and access to data via the app without the need for any personal data.

For our business clients (typically the BACK-TRACK user's employer) we know contact details such as names, phone numbers and email addresses and we will use these in a normal course of business. We will use them without requesting approval and our lawful basis for this would be it is in all our legitimate interests in the course of business to do so. We may publicise the names of clients within our promotional materials unless specified otherwise in a Non-Disclosure Agreement.

How the data is shared within the client (employer) organisation falls outside of the scope of this document (and our responsibility) and clients will have their own perspectives on this.

What Movement data do we collect?

The BACK-TRACK system utilises a small wearable device that collects movement data, the objective being to raise awareness to susceptibility to back pain or injury through undesirable lifting and handling postures. Back pain is very common, it is the leading cause of disability and many people can not work or live active lives because of it.

The BACK-TRACK device collects data that can have a direct impact on some of the factors that have been identified as elevating the risk of back pain. The BACK-TRACK device will record the following data;

1) When it was turned On
2) If the wearer stoops forwards to a low-level
3) If the wearer twists and stoops simultaneously to a low-level
4) If the wear jumps - typically from a vehicle's cab or tail-lift
5) If the wearer is active i.e. walking or inactive i.e. sitting
6) If the wearer is driving / travelling in a vehicle
7) When the device was turned Off

All events are time-stamped, ie the BACK-TRACK device will record the time each event occurred.

We refer to this as Movement data and whilst it is not necessarily personal data and you can not be identified by it, we think it is in everyone's interests for us to be transparent with what data we have and what we do with it.

How do we use your information?

We will produce graphs / tables summarising Movement data which may be shared with your employer in the legitimate interest of your ongoing health, safety and well-being.

Depending on how BACK-TRACK is implemented within your organisation, it is possible that your employer can run a report to identify who might be at an elevated level of back injury risk (identified by BACK-TRACK movement data) and this might be important to you.

If you are using BACK-TRACK as part of a rehabilitation programme, your employer will seek to support you in this and they will have their own procedures for doing this.

Data is stored in a database on BACK-TRACK Europe's dedicated servers and is processed in the EU. The database is accessible to a very limited number of BACK-TRACK Europe Ltd.'s employees, all of whom have received data protection training.

How long will we retain your data?

As we do not hold BACK-TRACK users personal data, we consider the risks associated with data retention to be minimal. We do not share it with anyone other than your employer who has legal responsibility for your occupational health and safety and therefore we will retain your data indefinitely. [Remember, as far as BACK-TRACK Europe Ltd. is concerned, this data is anonymous].

However, if our contract with your employer ends, your data will also be deleted from our servers.

Your rights

You have the right of access via the BACK-TRACK App.

We are registered with the Information Commissioner and you can request a copy of our certification from support@backtrack.co.uk

If you have a complaint about how we are managing or processing your personal data, you also have the right to complain to the Information Commissioner's Office at www.ico.org.uk/concerns

Direct Marketing

We will not contact you with offers from third-parties nor will we provide your contact information to a third party.

Cookies statement

Our website does not use cookies to track who visited us and when.

Contacting Us

If you have any questions about this policy or concerns about how we process your data, you may contact us at support@backtrack.co.uk