• We use Google Analytics to help us understand how people use our website and identify ways to improve it. Google Analytics collects information such as which pages are visited, how long people spend on the website and how they found us.

• The information collected is used to produce anonymous reports about website usage. Google Analytics does not identify individual users or use your IP address to identify you.

• Google Analytics processes the information on servers that may be located in the United States. You can find out more about how Google collects and uses data by reading Google’s Privacy Policy.

• If you prefer, you can disable or refuse analytics cookies in your browser setting or use Google’s opt-out tool. Please note, if you disable cookies or JavaScript, some parts of the website may not work as expected.  

What we do – and don’t do – with information about you

We will:

• Store the information you provide so that you can continue to access and make use of the NHS Healthy Living service

• If you consented on registration, make your information available to your GP as part of your direct care

• Use either your NHS app, email address and mobile phone number to send notifications from your chosen programme once registered. You will have the ability to adjust the frequency and type of notifications you receive in your settings, where you can also turn this function off completely

• Provide access to an administration area of the website for our staff to download/extract reports of activity, that are then reviewed by NHSE England

• If you consented on registration and your GP practice is connected via Promatica Digital Ltd, we may use the extracted report data to match against your routine care records (this may include HbA1c/blood glucose levels)

• Analysed and store all data in accordance with NHS standards for record management https://www.england.nhs.uk/long-read/records-management-policy/

• Provide access to a forum here you can choose to chat and share information with other users, if you want. Any personal or sensitive data added by yourself on the forum is at your own risk, we do not recommend the sharing of personal or sensitive data.

• Only share your screenname with fellow users. You will be asked to create a screenname during registration. This will be displayed if you interact with other users on the chat forum or take part in any activity challenge/leader boards

• Provide access to a secure Helpdesk service which allows you contact us for help with technical issues and questions via phone or to securely send questions to our Helpdesk via email or Chat. Your message will only be listened to/viewed by NHS admin staff trained to support you

• Provide you with the ability to synchronise your account with Google Fit, Google Health or Garmin. If you choose to sync your account, then we will share the information you have provided with Google or Garmin. Their use of your data is governed by their own privacy policies, rather than ours – see:

 https://policies.google.com/privacy

https://www.garmin.com/en-US/privacy/connect/policy/

We may:

• use the anonymous information you provide to, or the data extracted from your patient record by Promatica Digital Ltd, measure or understand the effectiveness of the two programmes available on the NHS Healthy Living website 

• Anonymised reports will be created from the data to better understand the impact of NHS Healthy Living Service and to inform future service delivery. These anonymised reports may be shared through publication in relevant health or medical journals and /or with NHS England, so we can provide the best digital diabetes education experience possible

• use the information you give us as part of the administration of NHS Healthy Living Service and for internal operations, such as troubleshooting, to improve our site and ensure that content is presented in the most effective manner for you and others using NHS Healthy Living website

• need to share information about your use of the site with our web hosting company, Promatica Digital Ltd, but only to the extent that is needed for the running and maintenance of the NHS Healthy Living website. Where possible this will not include any information which could be used to identify you personally. Our webhosting company and developers are subject to strict obligations of confidentiality and won’t be able to use your data for anything else

• ask you from time to time about your experience with the Healthy Living service, and use the information you provide to analyse and improve the service we offer you

• need to share your information with other organisations as part of our legal compliance obligations: for instance, the Care Quality Commission inspects UHL regularly and can ask to see the information we hold

• need to use your information in connection with legal proceedings, or to investigate and respond to any complaints you may make.

• need to share your data with UoL for evaluation purposes; by the time of sharing all data will be anonymised with a pseudonym user identification number so UoL staff are unable to identify anyone from the data shared.

• Publish our evaluation analysis, all data will be fully aggregated and anonymised at the point of publication

We don’t:

• share information with other users of the website

• share the information you give us with any organisations not previously mentioned.

The legal basis for processing your information

“Processing” means doing anything with your information, for example collecting, storing or deleting your information. Data protection law means that we can only use your data for certain reasons and where we have a legal basis to do so. Here are the reasons for which we process your data:

• The processing is necessary for us to comply with our legal obligations, such as obligations to provide a safe service. We are under legal obligations to have systems in place to proper records (under the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014;

• NHS Healthy Living service is provided by the UHL as part of the NHS and forms part of the exercise of our functions under the NHS Act 2006, which include the supply of health services.

Because our service is a ‘health’ service, we will also process ‘sensitive’ information (known as “special category personal data”). The normal legal basis for this is:

• The processing is necessary for the purposes of preventive medicine, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services;

• processing is necessary for reasons of public interest in the area of public health, such as ensuring high standards of quality and safety of health care.

We will respect your confidentiality and wherever possible, we will respect your wishes in terms of how we use your information.

Keeping your information up to date

It’s really important that the information you give us is kept up to date, so that you can monitor your progress yourself and so that those with an interest in your health, such as your GP, can find out how you are getting on (if consent to sharing was granted by you at registration).

You can keep your information up to date:

• by changing your information on your NHS Healthy Living Service account page – Select Settings in the Menu -, and

• on the specific information you provide on, for instance, your weight, blood glucose, and activity trackers – select Trackers or Activity in the menu bar to navigate to the relevant tracker.

How long we keep your information for, and when you stop using the NHS Healthy Living service

We keep information on your account for 24 months if the account remains active. After 24 months you will be offered the option to renew your account; if you agree you will continue to have access for another 24 months. This option will be made available every 24 months thereafter.  If the account is deactivated or unused all information is archived after six months, and any personal identifiable information removed after 24 months. This is so that we meet our compliance obligations, and in case you want to use the service again in the future.

Where your GP practice has shared information from your GP record with the service, this information forms part of a healthcare record and is subject to a different retention period. In line with the NHS Records Management Code of Practice, this data is retained for a minimum of 8 years from the date of the last entry, after which it is securely deleted. This applies even if your account has been closed or anonymised before that point. The GP-shared data is retained separately in a form that meets NHS records requirements, with access strictly limited.

You can find out more about the retention periods for healthcare related information in the NHS Records Management Code of Practice, available via https://www.gov.uk/government/publications/records-management-nhs-code-of-practice

Keeping your information safe and secure and where your data is stored

We use a range of physical, technical and organisational security measures and processes to keep your information safe and secure, such as:

• password login;

• encryption on our website;

• carrying out regular privacy impact assessments

• training for staff on information security and data protection;

• restricting the number of staff that can see identifiable information you provide to the website, only to those that need to know or see the information in order to do their jobs.

NHS Healthy Living platform is hosted by Promatica on Azure servers in the Azure UK South data centre. Azure Data Centres are ISO 27001, 22301 and PCI DSS certified. 

For the purposes of reporting, required anonymised data will be downloaded from NHS Healthy Living and transferred to the relevant NHS England data reporting portal by a member of UHL and/or Promatica staff.

The Healthy Living helpdesk is supported by Netcall’s contact centre platform called Converse CX. Converse CX is hosted on Amazon Web Services (AWS) in the London region. AWS is ISO 27001, 22301 and PCI DSS certified.

For the purposes of evaluation, required anonymised data will be downloaded from NHS Healthy Living and if necessary, shared via encrypted email to a member of UoL staff.

 If you choose to connect your account with Google or Garmin to use activity tracking features, or if you accept Google Analytics cookies to help us understand how our website is used, your personal information may be transferred and stored outside the UK. This is outside of our control. These third-party providers may process your personal information on servers located outside the UK. They are responsible for processing your personal information in accordance with their own privacy policies.

You can find out more by reading:

·       Google Privacy Policy (includes Google Fit/Health and Google Analytics): https://policies.google.com/privacy

·       Garmin Privacy Policy: https://www.garmin.com/privacy/global/

You can find out more about how the NHS keeps online information safe, and what you can do to help with this, by reading the guidance note at https://digital.nhs.uk/data-and-information/information-governance/guidance/records-management-code-of-practice/guidance-for-patients-and-service-users (link correct as of 25/08/2026)

Please remember:

• You provide information at your own risk: unfortunately, no data transmission is guaranteed to be 100% secure;

• You are responsible for your username and password: keep them safe and secure

• If you believe your privacy has been breached or infringed, please contact us immediately by emailing  uhl-tr.healthylivinghelpdesk@nhs.net

 Your rights

You have control over much of the information you supply to us by choosing what you input into the NHS Healthy Living website. You can limit this, but this may mean that your allocated NHS Healthy Living programme does not work well and may give you an inaccurate picture of your health.

You also have the right to:

• ask us to let you know what information we hold about you

• ask us to amend the information we hold about you if you think it is incorrect

• ask us to delete any information we hold about you

• ask to be withdrawn from NHS Healthy Living service

• ask us to limit the way in which we use your information

• ask us to send your information on to a third party

• make a complaint to the Information Commissioner’s Office about the way in which we have used your information. The ICO can be contacted by visiting  https://ico.org.uk.

You should however be aware that the accuracy and relevance of the programme will depend on the level of information you provide to us.

We will not make a charge in the first instance for providing you with the information we hold about you or.

You can contact our Data Protection Officer to find out more about how we use your information or to exercise any of your rights mentioned above, through the contact details at the beginning of this document.

How to withdraw from your NHS Healthy Living service

You have the right to withdraw your consent to the processing of your personal data at any time. If you have previously given consent for us to collect, use, or share your personal information, you may withdraw that consent by either: 

1. Going to your Account settings in the main menu and following the onscreen directions to close your account

2. Or by contacting us at  uhl-tr.healthylivinghelpdesk@nhs.net  - Upon receiving your request, we will stop processing your data for the purposes for which consent was originally given, unless we have another lawful basis to continue. We aim to respond to all correspondence within 2 working days.

Children

You must be aged 18 or above to use NHS Healthy Living service.

If you believe a child has accessed NHS Healthy Living service and/or provided personal data without parental consent, you can report this to uhl-tr.healthylivinghelpdesk@nhs.net. We aim to respond to all correspondence within 2 working days.

Changes to this policy

Any changes we may make to this privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy. This page was last updated on 30/09/2026.

How to contact us

You can contact us by emailing uhl-tr.healthylivinghelpdesk@nhs.net with any questions or concerns. We aim to respond to all correspondence within 2 working days.