Patient Reports: Defining SMS workflows with schedules, registration, and patient reports.
If you have any questions, please reach out to our Data Protection Officer at email@example.com.
As a non-profit organization, Medic Mobile (“Medic”)’s mission is to advance good health and human flourishing by building open source technology with and for hard-to-reach communities. We value humanity, creativity, initiative, solidarity, and openness. Being responsible stewards of people’s data is critically important to our mission.
We use the concept of Responsible Data (RD) to outline our collective duty to prioritise and respond to the ethical, legal, social, and privacy-related challenges that come from using data in new and different ways in healthcare, advocacy, and social change. We have an obligation to account for unintended consequences of working with data by:
As an organization, we promise to do our best to live up to these obligations. We promise to show initiative, to seek feedback, and to proactively seek out ways to work with data more responsibly. We promise to accompany patients, health workers, researchers, organizational partners, and our open source community in the journey from best intentions to best practices in data-driven projects. The purpose of Medic’s data policy is to help our organization deliver on this responsible data promise.
Medic serves as a technical partner to governments and non-governmental organizations around the world. As a result, our projects comply with a range of country-specific and region-specific data protection regulations, and the details of compliance are addressed on a project-by-project basis. Adhering to all data regulations that are relevant to a given project is a central element of Medic’s global privacy and data protection policy.
In most cases, the Ministries of Health, other government agencies, and non-governmental organizations that Medic supports (Medic “Partner(s)”) serve as data controlling entities, and they work with Medic as a business associate. Partners establish additional data handling policies and standard operating procedures, which are typically documented in Memoranda of Understanding or/and Data Sharing Agreements signed by these Partners as well as Medic.
Medic has developed an open-source software toolkit (“Software”) that combines smart messaging, decision support, easy data gathering and management, and health system analytics. The Software can be accessed via many types of devices, including feature phones, smartphones, tablets, and desktop computers. Certain aspects of the Software can be downloaded for use on such end user devices. Health workers and families can use the Software to help monitor pregnancies, track outbreaks faster, treat illnesses, keep stock of essential medicines, and communicate about emergencies, among other things.
The Software is made available to the public on a free and open source basis, under licenses approved by the Open Source Initiative. These licenses limit Medic’s liability or responsibility with respect to any uses of the Software in which Medic personnel are not directly involved in Processing Data (defined below). The Software source code and the relevant licenses can be accessed at http://github.com/medic.
Medic hosts, maintains and supports certain components of the Software on Medic managed servers where Data obtained by use of Software on end user devices is received, accessed, handled, and/or stored (collectively, “Processed”). “Data” means any and all data, information and other content uploaded, posted, input or transmitted to the Software, or generated by the use of the Software, by or on behalf of End Users.
Subject to compliance with applicable law, Medic and its permitted subcontractors and agents shall not disclose Data to any third party and shall not use or access the Data for any purpose, except the following specific purposes:
For the purposes of this policy, “Impact Metrics” refers to aggregated Data which does not include personally identifiable information or Protected Health Information (defined below), and which is useful for Medic’s charitable purpose of monitoring the use of the Software and understanding its impacts on health systems. Examples of Impact Metrics include the total number of households registered in the Software, the total number of health workers using the Software, the total number of households visited in a given month, and the total number of Software-supported actions on antenatal care, postnatal care, integrated community case management, family planning, malnutrition, and immunization services. It may also include aggregate Data concerning COVID-19 services such as community event-based surveillance, contact tracing, CHW self-checks, and support for self-isolation provided in Medic-supported projects.
Any Impact Metrics shared with the general public will be aggregated globally; Medic personnel shall not de-aggregate the Impact Metrics to identify activities in any particular Country, without obtaining prior written consent from the Partner(s) acting as the relevant data controlling entities. Examples of previously reported Impact Metrics are available to the public in Medic’s quarterly and annual reports, which can be accessed at https://www.medicmobile.org/research-impact-reports.
All additional uses of data for research and reporting will comply with applicable Ministry of Health policies and existing Partner policies for health data access and sharing. Medic personnel shall not use any Data for research purposes unless Medic has obtained the prior written consent of the relevant Partner(s), which may involve execution of a data sharing agreement.
For purposes of this policy, protected health information (“PHI”) is defined as any physically or electronically-encoded information containing at least one of the following:
Medic’s PHI policy requires that:
All Medic personnel sign a Protected Health Information (PHI) policy which mandates the use of full disk encryption, secure communication channels, and two factor authentication when handling PHI. This policy applies to all Medic personnel – including, but not limited to, employees, contractors, associates, fellows, interns, advisors, and board members. This policy applies to computer equipment and/or systems that are either: (i) property of Medic; (ii) property of any Medic personnel; or (iii) used directly by Medic personnel to carry out any assigned duties.
Exceptions to this policy may be granted – on a task-specific or project-specific basis only – at the discretion of the CPO or COO. This policy does not confer any ownership of data; Partner-submitted data remains in the control of Partner organizations. This policy does not apply to equipment stored in an authorized secure data center / facility (e.g. Amazon Web Services), or to equipment wholly owned and operated by an external Partner, or to external software deployments to which Medic has no access.
Medic is committed to data security. In addition to adhering to data security standards established by our Partners, we also recognize the security benefits and drawbacks of different technology tools and work with our partners to make the best choices and mitigate risk.
Web app: Medic uses secure transfers over HTTPS for all communication between the browser and our web application, with perfect forward secrecy (PFS) and 4096-bit SHA-2 certificates by default. We use a non-standard port for SSH access to reduce our exposure to automated brute-force attacks and can configure the web app to accept only public key authentication for SSH connections. Access to the web application requires a password, and user access can be established to varying degrees using a role-based access control facility (e.g. full access, restricted access, data entry only, and data export only).
Data storage: Medic uses Amazon Web Services (AWS) with enforced two-factor authentication, HTTPS, and Identity and Access Management (IAM) for all hosted instances. We use IAM policies on AWS to restrict what any one individual Medic developer/administrator can do. Please see below for more information on AWS data security.
SMS: We train users to input data using simple SMS codes or freeform SMS. We use “plain text encoding” which means viewers can see the value but not know the context of the data. As an example: when health workers text P 3 Jane (“P” for pregnancy, “3” for number of weeks pregnant, name), Medic registers the pregnancy, creates a patient ID, calculates the expected delivery date, and schedules automated reminder messages. SMS is inherently insecure but we work with every partner on safety practices to reduce and minimize mishandling of data and transmission of protected health information.
Android phones: To secure the data, each device must be configured to use Full Disk Encryption and a Screen Lock.
We work with every partner to make sure they are trained and equipped to handle their data. This includes advising partners on how to create secure passwords and PINs, how to secure hardware, and how to safely transport data.
For the purposes of this policy, Medic’s Chief Operations Officer serves as Medic’s Data Protection Officer. For any inquiries, please send an email to firstname.lastname@example.org with the words “Data Protection” in the subject line.
Patient Reports: Defining SMS workflows with schedules, registration, and patient reports.
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