Managed Self Ltd (“we”, “us”, “our”, “Klarity”), a company registered in England & Wales with company number 10696687 with registered offices at
Klarity / Managed Self Ltd
Alum House
5 Alum Chine Road
Westbourne Bournemouth
BH4 8DT
We are committed to protecting and respecting your privacy and ensuring the fair and transparent processing of your data. This Fair Data Processing Policy provides you with important information regarding the collection, use, and protection of your data within our online questionnaire and related services, particularly within Klarity’s screening programmes
Data Collection And Use
Types of Data Collected
Klarity collects self-reported data through our online questionnaire to assess your risk for various cancers. This data may include:
Personal health information (e.g., medical history, symptoms, genetic information)
Demographic details (e.g., age, gender, ethnicity)
Lifestyle information (e.g., diet, exercise habits, smoking status)
Device-related data (e.g., IP address, device type)
Purpose of Data Processing
The data collected is used for the following purposes:
Cancer Screening: To assess your eligibility and perform cancer screening procedures effectively.
Risk Prediction Models: To analyse your data using our proprietary AI and Generative AI models to determine your risk levels for different types of cancer.
Personalised Recommendations: To provide you with tailored screening recommendations based on your assessed risk levels.
Service Delivery: To facilitate the delivery of recommended screening tests, including at-home sample collection kits and clinic appointments.
THIRD-PARTY SUPPLIERS
Collaboration with Third-Party Suppliers
To deliver comprehensive cancer screening services, Klarity collaborates with several third-party suppliers:
The Mole Clinic: For skin cancer checks conducted at clinic appointments.
Scan.com: For mammographies and other radiological tests conducted at clinic appointments.
Bloodsandbeyond: For mobile phlebotomy services where full blood draws are required.
The Doctors Laboratory: For processing blood samples collected during screening.
These third-party suppliers are bound by confidentiality agreements and comply with all relevant data protection laws. Your data is shared with these suppliers solely for the purpose of providing the recommended screening services.
DATA SECURITY AND PROTECTION
Data Security Measures
Klarity takes data security seriously. We have implemented strict security measures to protect your data against unauthorized access, disclosure, alteration, and destruction. These measures include:
Encryption: All data is encrypted during transmission and storage to ensure its confidentiality and integrity.
Access Control: Only authorised personnel and systems have access to your data, based on role-based access control mechanisms.
Secure Storage: Data is stored securely in compliance with industry standards and GDPR requirements.
Data Lifecycle Management: We ensure the secure disposal of data when it is no longer needed, preventing unauthorized access.
DATA SHARING
Data Sharing Practices
Your data may be shared with:
Authorised Healthcare Professionals: For reviewing your screening results and providing necessary guidance.
Third-Party Service Providers: Such as Bloodsandbeyond and The Doctors Laboratory, for processing your samples and delivering screening services.
We do not sell or share your data with third parties for marketing or promotional purposes. Data sharing is limited to the minimum necessary to achieve the intended purpose.
If your data is transferred outside of the UK or EU, it is done so under contract, which states how those companies or individuals must keep your data safe. We ensure appropriate safeguards are in place, such as Standard Contractual Clauses, to protect your data during international transfers.
If your data is transferred outside of the UK or EU, it is done so under contract, which states how those companies or individuals must keep your data safe. We ensure appropriate safeguards are in place, such as Standard Contractual Clauses, to protect your data during international transfers.
Aggregated Data Sharing with Organisations
While we do not share individual screening results with the organisation funding the programme, we may share aggregated, anonymous data derived from our screening programmes with such organisations. This data may include metrics such as the total number of participants, the number of screenings completed, and general trends observed across the participant group. Such data sharing is designed to provide insights into the overall success and participation of the health initiatives, while strictly safeguarding individual privacy. All shared data is anonymised to prevent the identification of any individual participant.
DATA RETENTION
Data Retention Policy
Your data will be retained for a reasonable period, as required by applicable laws and regulations. We will not retain your data for longer than necessary to fulfil the purposes for which it was collected. When determining the relevant retention periods, we consider:
Contractual Obligations: Our obligations to provide you with services.
Legal Requirements: Obligations under applicable law to retain data for certain periods.
Legitimate Interests: Our interests in maintaining business records and improving our services.
Dispute Resolution: Potential disputes and claims
Once the retention period has expired, your data will be securely deleted or anonymised.
YOUR RIGHTS
As a data subject under GDPR, you have the following rights:
Right to Access: You can request access to your personal data that we hold.
Right to Rectification: You can request correction of inaccurate or incomplete data.
Right to Erasure: You can request deletion of your data in certain circumstances.
Right to Restriction of Processing: You can request restriction of processing your data under specific conditions.
Right to Data Portability: You can request to receive your data in a structured, commonly used, and machine-readable format.
Right to Object: You can object to the processing of your data in certain circumstances.
Right to Withdraw Consent: You can withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
To exercise any of these rights, please contact us at info@getklarity.io. We will respond to your request within one month.
DATA BREACH NOTIFICATION
In the event of a data breach that may pose a risk to your rights and freedoms, we will notify you and the relevant data protection authorities without undue delay, and within 72 hours if feasible, in accordance with GDPR requirements.
CHANGES TO THIS POLICY
We update our Fair Data Processing Policy from time to time to reflect changes in our data processing practices or legal requirements. We will provide you with an updated version on our website and notify you of significant changes.
Contact Information
If you have any questions, concerns, or wish to exercise your data protection rights, please contact us at:
Klarity (Managed Self Ltd)
Alum House
5 Alum Chine Road
Westbourne
Bournemouth
BH4 8DT
Email :info@getklarity.io
If you are not satisfied with our response to a complaint you have made, or think we aren’t complying with data protection law, you can make a complaint to the UK data protection regulator – the Information Commissioner’s Office:
ICO
Wycliffe House
Water Lane, Wilmslow,
Cheshire SK9 5AF
Email :casework@ico.org.uk
