Privacy at a glance
Patient responses and results are processed temporarily on the iPad. They are not sent to IDCP or its service providers. Apple purchase information and the licence or support details you send to IDCP are handled separately, as explained below.
A clinician may record the result in their own clinical system. For that separate patient record, contact the clinician or clinical organisation. For IDCP licence, support or privacy enquiries, use Support@idcpscotland.co.uk.
Controller and scope
IDCP Scotland Limited, registered in Scotland (SC666120), 77 Torrisdale Street, Glasgow, Scotland, G42 8PW. Contact Support@idcpscotland.co.uk.
This notice covers IDCP’s Peekaboo Vision app, listed on the App Store as “Peekaboo Vision - New”, for health professionals in Great Britain and related licensing and support. The initial release offers monthly and annual Apple subscriptions. Direct IDCP organisation licences are a future offering. IDCP is the data controller for its own licensing, administration and support records: it decides why and how those records are used. A clinical organisation remains responsible for the patient records it creates separately.
Patient assessment information
Assessment responses and the estimated acuity result are processed temporarily on the iPad. The app does not collect patient identifiers or send patient assessment responses or results to IDCP or its service providers. It does not retain identifiable patient results or assessment-response/score logs.
The professional may record a result separately in their own clinical system. That record is outside the app and is governed by the clinical organisation’s arrangements.
Local settings and access data
The app stores settings and licensing-related information on the iPad. This includes an installation identifier, access or expiry information and, for an organisation licence, organisation, seat, installation and issue/expiry identifiers. Access timestamps support entitlement and clock checks. These are not patient assessment records.
When requesting an organisation licence or technical support, you or your organisation administrator may send the necessary installation, licence and contact details to IDCP. Local settings and credentials follow the app and iPad storage arrangements; deleting the app does not necessarily remove all Keychain information.
Apple purchases and platform information
Apple handles subscription purchases and associated account, transaction and payment information under its own terms and privacy information. The app uses Apple StoreKit to verify access. IDCP does not receive your full payment-card details through the app. This purchase and entitlement processing is separate from patient assessment information.
The app does not use RevenueCat, Crashlytics or a comparable third-party analytics SDK. Apple may process platform or diagnostic information according to your settings and its services. Any technical information available to IDCP through Apple’s developer services is used for support, reliability and security; it is not intended to include patient assessment content. See Apple’s privacy information.
Organisation licences and support
Where IDCP handles organisation-licence enquiries or administration, its records are held in Microsoft 365 SharePoint. Direct organisation licences are not available at the initial launch. The register contains company name, contact name and email, licensed device count, installation and seat identifiers, issue date and expiry date as necessary to manage access. We receive these details from you or your organisation administrator.
Microsoft 365 hosts Support@idcpscotland.co.uk. Within IDCP, mailbox and licence-register access is restricted to the Managing Director and CEO according to their duties. We use support correspondence to answer requests, manage licences and investigate product issues. Send technical descriptions without patient-identifiable information. If a message raises a safety concern, necessary information is handled under our complaint and product-safety arrangements.
Purpose and lawful basis
We use necessary licence and support information to provide and administer access, resolve issues and meet applicable safety obligations. Contract is the basis where information is necessary to perform our contract with you personally or take steps you request before that contract. For organisation employees and administrators, our legitimate interests are supplying and managing the organisation’s access, resolving faults and protecting the service; the organisation’s contract is not automatically a contract with each employee. Legal obligation is the basis for records and reporting required by applicable product-safety and business law. We assess necessity and your interests before relying on legitimate interests.
We do not sell personal information or use patient information for advertising. Automated entitlement checks decide whether software access is current; they do not determine diagnosis or referral. If an access check appears wrong, contact support so we can investigate. An access check is separate from the clinician’s interpretation of an assessment. If necessary information is not supplied, we may be unable to issue a licence or investigate a support request.
Recipients and international processing
Relevant information may be processed by authorised IDCP personnel, Microsoft for mailbox and SharePoint services, and authorities where disclosure is required by law. Apple independently handles its account, billing and platform processing under its own privacy arrangements; it is not described here as IDCP’s general-purpose processor. Any professional adviser used for a specific dispute or legal obligation receives only necessary information under appropriate confidentiality arrangements. We disclose only what is needed for the applicable purpose. Providers processing information on our behalf must protect it under appropriate contractual confidentiality, security and data-protection obligations consistent with this notice and applicable requirements.
Microsoft storage and processing depend on the tenant and service configuration. UK/European service selection does not guarantee that every support, security or subprocessor activity takes place only there. A restricted transfer to a recipient in the Netherlands or another EEA country can currently rely on UK adequacy regulations. Other transfers require their own applicable lawful mechanism. You may request details or a copy of applicable safeguards through the support mailbox, subject to necessary confidentiality redactions. Website hosting in the Netherlands is covered by the website privacy notice; no patient results are uploaded to that website.
Unexpected health information
Do not send patient-identifiable information with routine licensing or support messages. If it is received, access is restricted. We notify the sender without repeating patient identifiers and request a redacted resubmission. Routine investigation may need to wait for usable information. Unnecessary detail is minimised or removed securely, subject to documented legal retention obligations. We still assess the necessary facts of a product complaint or safety concern; the inclusion of patient information does not invalidate the complaint or suspend applicable reporting duties. Where a safety investigation requires identifiable health information, we will explain the applicable processing basis and arrange a suitable secure route. A licence or routine support request does not give consent for unrelated health-data processing.
Retention
The following periods apply to IDCP’s records. They do not describe a patient-record database in the app.
- General enquiries: 12 months after closure.
- Routine technical support: 24 months after closure.
- Organisation licences and associated commercial records: the active term plus six years after expiry or termination.
- Routine website access logs: 30 days from creation.
- Website security-incident records: 90 days after closure, unless an investigation or legal hold justifies longer retention.
- Product complaints, safety incidents and post-market surveillance (PMS): ten years after record closure and, if later, through the end of the applicable device-model PMS period, subject to any longer legal requirement.
- Privacy requests: three years after closure, keeping only necessary request and outcome evidence.
Necessary safety records follow the product-complaint schedule, even if first received as a support email. We review expired records quarterly for deletion or irreversible anonymisation. A documented investigation, dispute or legal hold may require longer retention; we review that need regularly.
Backup copies, recycle bins, version history and service audit logs follow the relevant recovery and supplier retention arrangements. Deleting an active record does not necessarily remove every recovery copy immediately. We restrict access to retained copies and do not use them for unrelated purposes.
Patient assessment information is handled temporarily for the assessment session, not retained as an IDCP clinical database. Read the instructions for use for session operation and result handling. Record the result in your clinical system before leaving the result screen; the app is not a patient-record system. The company-record periods above do not set a retention period for temporary on-device patient responses. Local settings, credentials and access information follow app/device behaviour. For help removing IDCP-controlled licence or support information, request deletion through our support mailbox. Uninstalling the app does not cancel an Apple subscription and may not clear Keychain information. We explain any data that must be retained and why. Do not erase access credentials during an assessment. We do not promise immediate erasure from Keychain, platform records or backup copies.
Your rights and contact
Depending on the processing and applicable conditions, you can request access, correction, deletion, restriction or portability of your personal data. Where consent is used, you can withdraw it without affecting earlier lawful processing. Contact us to exercise your rights; we may need proportionate identity checks. You may complain to the Information Commissioner’s Office. Contacting IDCP first does not remove that right.
Your right to object: you can object to our use of your personal information based on legitimate interests. Contact the support mailbox and explain your circumstances. We will consider your objection under the applicable data-protection rules.
For access and other individual-rights requests, we respond without undue delay and normally within one month, subject to the applicable legal rules. If a lawful extension or clarification is needed, we explain it and the applicable timetable. Exercising a right does not require you to use a particular email subject or form.
To complain about our handling of personal information, email Support@idcpscotland.co.uk or write to our registered office. Describe the concern and how you would like us to contact you; do not include unnecessary patient information. We acknowledge data-protection complaints within 30 days, investigate appropriately, keep you informed and communicate the outcome without undue delay. Jamie Thomson coordinates handling; you may request escalation to Jan Boers through the same contact. This does not restrict your right to contact the ICO.
Send privacy requests to Support@idcpscotland.co.uk. We will route your request to an authorised person. We can address records held by IDCP; requests concerning your clinician’s patient record or your Apple account may need to be directed to that organisation.
Changes
We will identify the effective date when this notice is issued and update it if app or service processing changes. Information in the final app and App Store privacy disclosures must describe the same release behaviour.