This document outlines the personal data processing of user data from the Záchranka mobile application. This data processing is governed by legislation, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council, referred to as the GDPR – the General Data Protection Regulation.
II. The personal data controller
The Operator of the Záchranka app system (hereinafter referred to as the ‘app’) is the non-profit organisation Aplikace Záchranka, z.ú. (the Záchranka application), registered address: Vachova 43/5, Brno, 60200, Czech Republic, Company Reg. No.: 05435773. The key partner for the operation of this system is the Zdravotnická záchranná služba Jihomoravského kraje (South Moravian Regional Emergency Medical Service) organisation, Company Reg. No.: 00346292 (hereinafter referred to as ‘EMS South Moravia’). EMS South Moravia is, within the meaning of GDPR, the controller of personal data sent via the app in an emergency situation in combination with the call to the 155 emergency line.
III. The personal data processed and purpose of processing
The Operator shall process users’ personal data entered into the app by users during the registration process and in the app’s ‘My Profile’ section.
Mandatory registration constitutes the submission of a mobile phone number and full name. This data is then used to generate the registration code that is sent to the aforementioned mobile phone number submitted. By entering the registration code in the app, the app is then activated and in the event of an emergency, the system’s own emergency messages are then able to be sent to the units of the integrated rescue systems in the Czech Republic, Austria, Hungary, and in areas covered by the Slovak mountain rescue service.
Users also have the option to add and edit the following additional health/personal information in the ‘My Profile’ section:
- Email address
- Year of birth
- Permanent address
- Social Security/Health Insurance number
- Native language
- 2 next-of-kin contacts (phone numbers)
- Health details by selecting YES/NO (diabetic, heart problems, lung problems, deaf, blind)
- Add editable text further describing the user’s health details (e.g. prescribed medications, allergies etc.)
- Add editable text describing the user’s current health details or temporary illnesses, current location or further identification data, with the option to set a time limit for automatic deletion of this data
- All entered data is stored solely in the Záchranka mobile app and is only ever transferred when users deliberately press the emergency button in the ‘Alarm’ module. By pressing and holding the red button for 3 seconds, an emergency message is sent. It contains all data that users have entered in their ‘My Profile’ section. The emergency message always contains the user’s GPS location at the time the emergency button is pressed, along with details of their mobile’s language settings, battery and signal statuses, internet connection, and the version of the app currently installed.
The data is sent either by secure data transmission or by SMS to the Information System of South Moravia EMS. Based on the GPS location contained in the emergency message, this information is then forwarded to the relevant regional EMS for handling that rescue operation. By sending data from a mobile phone to the South Moravia EMS system, the user data becomes part of medical documentation and is thus subject to the rules governing these purposes, as set out by law. Sending data in an emergency message is the equivalent to providing such information during a voice call to the 155 emergency line. The 155 emergency call is still, however, an integral part of activating the ‘Alarm’ button.
Social Security/Health Insurance numbers are used by the rescue services to retrieve user information that users may have stored in the ZDRAVEL electronic medical records system.
All transferred data is considered part of the medical documentation and may only be used in the context of a rescue operation or for the subsequent processing of anonymized data analysis and statistics within the rescue services.
The Operator shall not be responsible for the accuracy of personal data processed by the app. In the event that the Operator shall be demonstrably aware of the inaccuracy or incompleteness of the processed data hitherto provided by the user, they shall be obliged to correct, supplement or delete such data in the prescribed manner.
IV. Legal titles of processing
The Operator shall process personal data on the basis of the user’s acceptance of the conditions during the installation of the app.
V. Duration of processing
South Moravia EMS shall store the data on the app’s central server for a maximum of two years. This shall be only user data that was transmitted to South Moravia EMS, i.e. the Záchranka app data of those users who have used the app to call for help.
VI. Personal data security
The Operator has taken appropriate technical and organisational measures with regard to the technology, financial costs, nature and purpose of processing. The Operator has ensured an adequate level of security for personal data transferred as part of an emergency call to the central server at South Moravia EMS, taking into account the risks of accidental or unlawful destruction, loss, alteration, unauthorized access or other forms of unauthorized data processing.
The Operator shall undertake to comply with the above measures with regard to the development of new technologies and to eliminate possible future threats to the system.
Employees of the Operator, and other persons who process personal data on the basis of a contract with the Operator, and other persons who come into contact with personal data in the performance of their rights and obligations are obliged to maintain the confidentiality of personal data and security measures, the disclosure of which would jeopardize the security of personal data. The obligation to maintain confidentiality does not apply to the obligation to provide information under special laws.
VII. Processing methods
Personal data is processed exclusively in automated electronic form.
VIII. Recipients of personal data
Recipients of personal data include employees of regional EMS services and other units of the rescue service system participating in the rescue operation (the water rescue services, mountain rescue services, etc.)
IX. Additional processing principles
Registered users of the Záchranka app may request the deletion of personal data that has been transferred as part of an emergency call via the app. Deletion may be performed by the Operator or an employee of South Moravia EMS.
X. Contacting the Data Protection Officer
The Data Protection Officer can be contacted by email at: email@example.com