Barbados and countries around the world are currently battling the COVID-19 pandemic. In Barbados, this has resulted in the Government of Barbados declaring a Public Health Emergency.
The BIMSafe mobile user application (the “App”) is offered by the Ministry of Health and Wellness, working with the Ministry of Innovation, Science and Smart Technology and other key partners as part of Barbados’ strategy for effectively managing the impact of COVID-19 on our society.
Table of Contents
- Who are we?
- What does the BIMSafe App do?
- What information are we collecting from you and why?
- Who will we share your information with?
- What is our legal basis for using your information?
- Will your information be secure?
- How long will the information be kept for?
- What are your privacy rights?
- What about updates to this policy?
- Who do you contact about this policy?
The Government of Barbados, acting through the Ministry of Health and Wellness (“We” or the “Ministry”) is a data controller within the meaning of the Barbados Data Protection Act, 2019-29 (the “BDPA”). The Ministry determines how and for what reasons your personal information is processed by the App. You may contact the Ministry via the information provided below.
The App is a location and symptoms monitoring mobile app developed by the Ministry to assist in the prevention of the spread of COVID-19 in Barbados. It is required for use by all travelers to Barbados and has several features to improve your travel experience.
- Provides information that educates and increases awareness among users of the App by outlining relevant protocols, rules, restrictions and news;
- Assists users with border entry by validating information provided by the users against the Ministry’s protocols, thereby facilitating expedited processing at the airport;
- Supports quarantine/restricted movement efforts of the Government of Barbados by helping to ensure that users remain in approved accommodations during the quarantine or isolation periods in accordance with the Ministry’s protocols;
- Allows symptoms reporting to the Ministry; and
- Provides access to care and support where the user’s reported symptoms suggest a COVID-19 infection by allowing relevant officials to guide the user to appropriate care contacts and testing access.
The privacy of your information is important. Protection of your personal data is a core pillar of the Ministry’s response program. When you install the App, no user registration or password is necessary. Identifiers provided to you by other official Government services are entered into App, allowing the App to communicate other information about you to existing secure systems.
Any information collected by the Ministry about or from you that can be used to identify you – either by itself or, together with other information in the possession of the Ministry – is considered personal information. Sensitive personal information refers to any personal information collected by the Ministry that can reveal your racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data; health data or data concerning your sex life or orientation.
Below is a list of all the different categories of personal information and sensitive personal information. that the Ministry collects via the App and an explanation of why each is collected:
- If you are required to quarantine, you may be provided with a wearable device that interacts with the App. Where a wearable device is connected to the App, the Ministry will collect the following information: (i) the location you are quarantining at, (ii) the GPS location of your phone, and (iii) whether the wearable device is nearby. That information is captured to determine whether you are abiding by the relevant protocols that require you to remain within the range of the quarantine location.
- You may elect to provide Nicknames to travel codes. Doing this makes it easier for you to monitor your information through the App.
- Travel codes originating from Barbados immigration forms are used to tie your device and the App’s activities to a known identity, helping to ensure your safety and compliance with health protocols while travelling. Travel codes may be collected utilising your device’s camera function to scan QR or bar codes.
- A device gateway is used to uniquely tie your device to travel codes, thereby allowing the App to communicate with you, wearable devices via your device’s Bluetooth service and provide you with support and information from the Ministry.
- If you are an inbound traveler to Barbados, the App searches a local health database containing your personal information from the Barbados Immigration Department, including your name and date of your arrival to verify that the travel code entered is legitimate. This information may be used by the Ministry to contact you: (i) regarding denied border entry paperwork, (ii) in the event of contact exposure, (iii) if a breach of quarantine occurs or (iv) if the symptoms information entered in the App meets the threshold for alerting the Ministry.
- If the user also possesses an appropriate wristband, the App may collect GPS location data and communicate your wristband status via Bluetooth to enable government restricted movement monitoring reducing the spread of COVID-19, even when the app is closed or not in use. If a user seeks wristband support via the ‘Diagnose’ option, your connected wifi SSID is relayed to Ministry to assist in troubleshooting.
- Device permissions will be requested by the App. Where appropriate, these requests will seek your permission for the App to access your location/activity, camera, bluetooth, storage, and SSID. If your device runs an Android operating system, kindly also note that the App may read the following personal information from your device: These permissions can always be managed in your phones OS App Settings.
- GPS Location from ACCESS_COARSE_LOCATION, ACCESS_FINE_LOCATION is used to gather the latitude/longitude coordinates of your device and compare it to the coordinates of your approved quarantine location. This assists the Ministry with monitoring compliance with the restricted movement requirements. Only the Ministry has access to this data.
- SSID/BSSID from ACCESS_WIFI_STATE is used to communicate network state information to the Ministry to troubleshoot network/wifi performance, where you are required to quarantine. Only the Ministry has access to this data.
- Bluetooth from BLUETOOTH, BLUETOOTH_ADMIN is used to connect the BIMSafe wristband to the traveller’s device. Bluetooth will also report to the Ministry if the wristband is no longer in sufficient proximity or has lost connection with the device. This is done to monitor your compliance with the protocols. Only the Ministry has access to this data.
- CAMERA and Audio/Video From CAMERA + RECORD_AUDIO is used to scan QR codes or take photographs of tests/vaccinations documents for validation. This assists the Ministry with border entry by pre-approving travelers before arrival. Only the Ministry has access to this data.
- Files from READ_EXTERNAL_STORAGE, WRITE_EXTERNAL_STORAGE are used to allow you to upload tests/vaccination pictures or PDFs for validation by the Ministry. The purpose of this is to assist the Ministry with border entry by pre-approving travellers before they enter Barbados. Only the Ministry has access to this data.
- ACTIVITY_RECOGNITION is used to recognize device movement to register your location in a timely manner. This shows the Ministry your compliance with restricted movement requirements if you are required to quarantine. Only the Ministry has access to this data.
The permissions listed above can always be managed in your phone’s operating system settings.
- Diagnostic information may be sent to the Ministry at your request and in conjunction with a ticket ID which may be obtained by emailing the Ministry for support. The diagnostic information can assist in clarifying false breaches, aiding in repair of wristbands, and more. In utilising the ‘Diagnose’ options of the app, your network SSID is relayed to Ministry staff to assist in troubleshooting.
Sensitive Personal Information
- If you are required to report symptoms, the Ministry will collect symptom-related information via a health questionnaire about whether (i) whether you have trackedbeen tracking your symptoms on the required schedules, and (ii) if the symptoms information you entered suggests that you constitute a public health risk. In the latter case, the information, if it meets the threshold, will trigger an alert to the Ministry. Any symptom information entered is not retained in the App or transferred out of the App.
- PCR test and vaccination upload information is collected from travelers to ensure the safety and health of all parties. The information is used to make approval/denial decisions around border entry, per Barbados’ travel protocols. The App may use your device’s Camera or seek access to Device Storage to assist you in uploading your proof of vaccination and/or PCR test result. The information is used for purposes of border entry in accordance with the applicable health protocols.
- Assignments of Quarantine are made to facilitate the ongoing monitoring of your presence at an approved location in accordance with the applicable health protocols. The ongoing location awareness coupled with wristband proximity is leveraged by the Ministry only if breach events have occurred. If a breach event has occurred, you might be contacted for further questioning.
- A microsite is available to help upload vaccination/test records if not available on your phone. To initiate such an upload request via the microsite, one must enter an email address. The email address will be sent a message with a link to conduct the upload.
Any information you share with the Ministry via the App will not be shared with other Government ministries, public bodies or private third-party entities unless they are part of the Government’s overall strategy for responding to the COVID-19 Public Health Emergency.
The complete list of those who have access to this information and why they have this access are detailed below:
- Data may be shared with the Barbados Police Service to assist in enforcing a quarantine compliance breach.
- Data may be stored on secured third-party servers from time to time. The Ministry only stores data in this manner after satisfying itself that appropriate security measures are in place to properly safeguard the data.
The Ministry wishes to assure you that the personal information collected via the App is not shared with any other party.
The Ministry will only use your personal information where we have a lawful basis for doing so.
In every case, the lawful basis will be one of the following:
- Where you give us your consent to process your personal information. You can withdraw your consent at any time by contacting us via one of the contact channels below;
- To protect your vital interests in those circumstances where the information you self-report via the App indicates a risk to your own health such that you may not be able to expressly consent to us processing information that may be useful to save your life;
- For the Ministry’s legitimate interest, where it is necessary for us to understand how users like you use the App, and to improve the App;
- To comply with the Ministry’s legal and regulatory obligations as well supporting enforcement of applicable laws including the Emergency Management Act.
Any personal information you provide via the App will be held in accordance with the standards outlined in the BDPA and the Government of Barbados’ own security-related standards.
The Ministry will ensure that appropriate organisational and technical measures are utilised to safeguard your personal information from unauthorised access, the deliberate or accidental destruction of data and the loss of data. These measures include, where appropriate, the encryption of data. At all times, the security of any personal information you provide will be determined with reference to the context of the processing, the sensitivity of the data, the costs of securing the data, the purpose for processing the data as well as the severity and likelihood of risk to your rights and freedoms.
The Ministry will not keep personal information longer than necessary for the App to function effectively.
Data in the App is stored for the lesser of 60 days or until a user’s account is deleted.
Do note that accounts will not be deleted while they contain active symptom or quarantine status. If a user of the App’s information suggests an active symptom or quarantine status, deleting the App will not also automatically delete the personal information in that circumstance.
You have several rights under the BDPA that allow you access to data related to you as well as some degree of control over what data the Ministry may process on your behalf, how it should be processed, whether it should be processed at all and for how long it should be retained.
Except as limited under any applicable law, these rights include:
- A right of access – means that the Ministry must inform you of, and request access to, the personal information it processes about you;
- A right to rectification – you have a right to ask the Ministry to amend or update your personal information where it is inaccurate or incomplete;
- A right to erasure – this right means you can ask the Ministry to delete your personal information;
- A right to restrict processing – you can ask the Ministry to temporarily or permanently stop processing all or some of your personal information;
- A right to object
- the right, at any time, to object to the Ministry processing your personal information on grounds that should it continue to do so, it will likely cause you damage or distress;
- the right to object to your personal information being processed for direct marketing purposes by or on behalf of the Ministry;
- A right to data portability – under the BDPA you have the right to request a copy of your personal information in electronic format and the right to transmit that personal information for use in another party’s service;
- A right not to be subject to automated decision-making – you have the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect or otherwise significant effect on you;
- A right to withdraw your consent at any time in respect of the processing of your personal information where the basis for processing the information was your consent.
From time to time the Ministry may make changes to this policy to reflect changes in how the App functions. If these changes significantly impact how the Ministry will process your personal information, the Ministry will alert you via email, if you have provided one to the Ministry.
At no point will your rights be less than they are now.
This policy was last updated on November 25, 2021.
To exercise any of your rights, please send requests via email to email@example.com.
You may otherwise contact the Ministry at:
Ministry of Health and Wellness
Frank Walcott Building
Phone: +1 (246) 536-3800
The Ministry will respond to any legitimate written requests within one month. If your request is unfounded, repetitive, excessive, or if the Ministry cannot identify you, the Ministry is entitled to refuse to act on your request.
Do note that you also have a right to complain to the Data Protection Commissioner if you believe any of your rights under the BDPA have not been respected by the Ministry or another entity. You may contact the Data Protection Commissioner at +1 246 536 1212 or via email at firstname.lastname@example.org.