Note: Teva and NSHI may also be referred to in this Privacy Notice collectively as "we", "us" and "our".
"Programme" means the CareTRx™ programme which is devised, funded and run by Teva Pharmaceuticals, together with National Services for Health Improvement (NSHI). The programme supports and guides patients who have been provided with a CareTRx™ Sensor and access to the supporting smartphone CareTRx™ App, call centre and website.
"Personal data" means information that relates to any living identifiable individual (e.g. you, as a patient or a nurse, or a GP).
"Teva" means Teva UK Limited.
"NSHI" means National Services for Health Improvement, the nurse provider for the Programme (NSHI).
"Atlantis” means Atlantis Healthcare Limited
"NHS Test Bed" means the NHS Test Bed taking place in Sheffield to evaluate CareTRx’s potential to help those living with asthma. Teva is an innovator partner taking part in the NHS Test Bed.
The CareTRx™ Programme is designed to support patients with asthma to encourage supported self-management of the condition through providing innovative technology and patient support. It is also designed to help healthcare professionals understand and improve healthcare services.
The Programme runs for 6 months for each patient, and the data captured through your use of the technology and questionnaires will help Teva understand the patient experience in using CareTRx™. If you give your consent, some of these outcomes may be shared with the NHS for it to evaluate various healthcare services and improve care.
Teva and NSHI will work together to provide the Programme to patients using the CareTRx™ Sensor and CareTRx™ App and both parties are responsible for collecting and processing your personal data as part of this Programme.
This Privacy Notice describes how we collect and use your personal data to allow us to provide the Programme services and applies to information we collect from you or your GP’s practice at the start of your engagement with the Programme. We may update and add to this information as long as you remain within the Programme. It also applies to any information collected about you through the CareTRx™ App. Any updates to this Privacy Notice will be communicated to you.
In order to register for the Programme, you need to read the following information carefully, and sign the consent form at the end. Unless you provide us with your consent, we will be unable to enrol you in the Programme and provide you with Programme Services.
The Programme Services include:
The personal data that we may collect about you to provide the Programme Services is:
Some of this information is considered by law to be "sensitive personal data" about you. This includes any information that tells us about your health.
This information is only processed when relevant and necessary to ensure that you are given the appropriate guidance and support based on your specific circumstances, and to allow the Programme to be evaluated and improved. All the information we collect in relation to you is processed on the basis of your consent. We seek separate consent for any processing that is not strictly required to provide you with the Programme services, such as providing information back to your GP through a clinical report also available on the CareTRx™ App, or using your data with other patients' data to analyse the effectiveness of the Programme. You may withdraw your consent at any time, but if you withdraw your consent to the core Programme processing then we may not be able to provide you with the Programme services.
In providing the programme, we may use your information to:
Part of the Programme's services will be the assessment of your responses to questionnaires (such as the Morisky Medication Adherence Scale) in the Programme database, which the system and staff will use to assess your belief and attitude to your disease and treatment. This will help our staff to tailor individual patient communications.
Teva or a Teva affiliated company may also use your information to:
Where you provide your consent, we may share information collected about you as part of the Programme to your nominated GP. This information will be provided in the form of a report on your use of your Connected Sensor and your recent inputs into the CareTRx™ App. A copy of the most recent version of this report can be viewed and downloaded by you in the CareTRx™ App.
This sharing may allow your GP to integrate the Programme into your care, if they desire. You may withdraw your consent to this sharing at any time, but you will need to contact your GP to seek the deletion of any data shared before you withdrew your consent. Where you wish to change your GP, you will need to inform NSHI, by contacting CareTRx™ Support Services.
We may, where you have provided NHS Sheffield with your consent, share information collected about you as part of this Programme with NHS Sheffield in order to allow it to evaluate the NHS TestBed. For more information on how NHS Sheffield may use this data, please contact CareTRx™ Support Services.
Where you are a nurse, we collect personal data about you when you interact with patients who participate in the Programme and when you interact in the CareTRx Dashboard or Atlantis OTI CRM. In many cases, you will provide this information yourself by recording information in these databases. We collect and use this information to allow us to offer the Programme to patients, to ensure that there is an record of all interactions with a patient and to allow NSHI and Teva's processor Atlantis to provide Teva with reports on the performance of the Programme.
The personal data that we may collect about you for these purposes is:
We process this data on the basis of our legitimate interests in providing the Programme Services and evaluating the Programme's performance. NSHI may also process this data to perform and administer their contract with you.
Whether you’re are a patient or a nurse, whilst you are part of the Programme we retain all the information we gather about you in the CareTRx™ System and Atlantis OTI database. This information is accessible to NSHI staff directly involved in your care as a patient (such as nurses, call-centre staff, and programme managers) and Teva and NSHI staff and their processors who need access to administer, support or evaluate the database.
If you are a patient, and choose to leave or become ineligible for the Programme, NSHI and Teva will archive your information. We do not process this data on the basis of your consent, but instead we retain an archive copy of your data in order to meet our obligations to maintain records of the care offered by our Programme and to meet pharmaceutical regulation requirements, and to protect ourselves against legal claims linked to the Programme. Your information may also be archived if you become inactive and we are unable to contact you. We retain this information for as long as necessary to meet these objectives.
You may be entitled under applicable law to ask NSHI or Teva for a copy of your information, to correct it, erase or restrict its processing, or to ask us to transfer some of this information to other organisations. You may also have rights to object to some processing and, where we have asked for your consent, to withdraw this consent. These rights may be limited in some situations – for example, where we can demonstrate we have a legal requirement to process your data. As set out above, this can mean that we retain your data even if you withdraw your consent. To exercise your rights, please contact NSHI in writing or by e-mail at the addresses given below. NSHI may also require you to provide proper identification before it complies with any request.
We hope that we can satisfy any queries you may have about the way in which we process your information. If you have any concerns about how we process your data, you can get in touch using the contact details set out below. However, if you have unresolved concerns you also have the right to complain to the Information Commissioner.
Teva and NSHI take measures to secure your personal data from accidental loss and from unauthorised access, use, alteration or disclosure. Data is transferred securely using secure socket layer (SSL) encryption, and stored on secure servers. Additionally, we take further information security measures including access controls, stringent physical security and robust information collection, storage and processing practices.
The CareTRx™ Dashboard shall be hosted by Teva’s third-party supplier at its data centres within the European Union. Some support to these data centres and other technical and administrative support may be provided by suppliers located outside the European Union. Teva's supplier Atlantis, for example, provides support from New Zealand – a country that is recognised as meeting European Union standards. Teva and NSHI will ensure that your personal data is adequately protected in the event of any processing outside of the European Union.
Where information is transferred to another supplier outside the European Union, such as Teva’s subsidiary Gecko Health Innovations, Inc. located in the United States, these are protected through the use of signed Commission approved Standard Contractual Clauses unless the recipient is in a country which has been approved by the European Commission. You may request to see a copy of the clauses.
If we decide to change the substance of this Privacy Notice, we will provide you with a new notice. If required, we will obtain your consent.
Both NSHI and Teva are data controllers in respect of the processing of the personal data in the Programme.
If, at any time, you have questions or concerns about this Privacy Notice, please contact NSHI online. You can also get in touch with NSHI’s data protection officer, Eddie McKnight at Eddie.email@example.com or 01760 721729.
NSHI will use reasonable endeavours to answer your question promptly or resolve your problem.
NSHI is an independent service provider focusing on the effective creation and implementation of key healthcare strategies in order to deliver measurable outcomes on behalf of UK and Global clients whose principal place of business is at:
NSHI Limited, White House, 46 Station Street, Swaffham, Norfolk, PE37 7HP United Kingdom:
The provision of the Programme is sponsored by Teva, a leading supplier of medicines to the NHS whose principal place of business is at:
Teva UK Limited, Ridings Point, Whistler Drive, Castleford, WF10 5HX United Kingdom
Teva UK can be contacted at firstname.lastname@example.org