Oshn Pilot Project Privacy Notice

This Notice concerns Oshn - a digital therapeutic app for people aged 13–25. It is intended to support the self-management of low mood and reduced motivation. It is based on Behavioural Activation (BA), a type of Cognitive Behavioural Therapy (CBT), and psychoeducation, which helps users understand the link between thoughts, feelings, and behaviours, by suggesting value-aligned activities.

BFB have collaborated with the Mental Health Research for Innovation Centre (M-RIC). Their administrative offices are at University of Liverpool Knowledge Quarter L3 5TR Liverpool. We are collaborating on a research project entitled:"Oshn: Evaluating a mobile app for low mood and motivation among young people”. This project will help us understand:

Whether young people find Oshn easy and enjoyable to use
Whether it is safe and appropriate
Whether it helps improve mood and motivation

We will look at things like how often the app is used, how satisfied users are, whether any problems come up, and whether there are any changes in mood or daily functioning after using the app.

By learning from this early evaluation, we hope to improve Oshn and make sure it can be a helpful tool for young people who are experiencing low mood or motivation.

When you participate (over 8 weeks) in the project your personal information will be collected by BFB and further processed.

Introduction

BFB Labs Limited (‘BFB’) the creators of Oshn recognise the importance of protecting your personal information.

BFB is committed to complying with data protection legislation and, as part of that, being transparent with you about the use of your personal information when you use Oshn.

This Notice seeks to ensure transparency. It is important for you to read it before deciding to provide your personal information. It should be read alongside the Participant Information Sheet and any other information provided by M-RIC as part of their research.

Who are the Data Controllers?

For the collection of your information within Oshn (and passing it to M-RIC) BFB are the Data Controller. That is because we have decided to trial the product and to pass information to M-RIC who will conduct independent research. We may also consider any feedback you provide to us as developers when you use Oshn.

BFB’s registered office is 127 Farringdon Road, C/O Better Space, London, England, EC1R 3DA.

We are registered at Companies House under company number 09700274.

Our Data Protection Officer can be contacted via support@bfb-labs.com.

We are also registered with the Information Commissioner's Office (ICO) under number ZA393479.

Who are BFB?

We are developers of Oshn - as stated above it is based on Behavioural Activation. It is based on a simple idea: that what you do shapes how you feel.

Oshn helps users understand the link between thoughts, feelings and behaviours (psychoeducation), discover their values, and suggests quick ‘in-the-moment’ activities aligned with those values.

Even a few minutes spent on a meaningful activity can make a difference, helping users feel more engaged and being able to self-manage difficulties they may be facing with low mood and reduced motivation.

Oshn is not intended to diagnose, monitor, or treat any medical condition.

What happens when you use Oshn?

You download Oshn, register with the App and create a personal profile by providing basic details.
You go through the initial psychoeducation content to understand the link between thoughts, feelings, and behaviors, which is the foundation of Behavioural Activation (BA).
You identify personal values (up to 5 out of a list of 24), which helps tailor subsequent activity suggestions for you.
You review and select quick, 'in-the-moment' activities, which are aligned with your chosen values and life areas.
You engage with and complete either in the moment or scheduled activities. These are rewarded. There will be a weekly questionnaire to complete within the App itself.

The information is stored in an online hub created by BFB called ‘Vitamind’.

During the project

BFB will securely pass information collected about you to M-RIC for them to evaluate it.

    
                What data will be collected and/ or further processed
            
            Why is it collected and/ or further processed
        
            Name / Nickname

            Unique identifier of the user (not processed).
        
            Date of Birth
            Demographics of the study sample + Feasibility of collection for MHSHS reporting (NHS England anonymised reporting done monthly, mandatory for orgs providing mental health care for NHS patients)
        
            Gender
            Demographics of the study sample + Feasibility of collection for MHSHS reporting
        
            Ethnicity
            Demographics of the study sample + Feasibility of collection for MHSHS reporting
        
            Details of any disability
            Demographics of the study sample
        
            Details of any neurodiversity
            Demographics of the study sample
        
            Details of care experience
            Demographics of the study sample
        
            Postcode
            Demographics of the study sample + Feasibility of collection for MHSHS reporting
        
            Email
            Unique identifier of the user (not processed)

            Your short listed values
            Insights for user and internal reporting for productimprovements
        
            Records of your activity
            Insights for user and internal reporting for product improvements
        
            Your feedback
            Insights for user and internal reporting for product improvements
        
            Outcome Rating Scale
            Insights for user and outcome measure for study

What is the legal basis to collect and further process personal data

Processing of your data by BFB is done with your consent (explicit in the case of special category data).

Where consent is provided it can be readily withdrawn. If you wish to withdraw consent or have any other concerns please email BFB at support@bfb-labs.com

Who is personal data shared with?

Other than with M-RIC information about you is not shared with anybody outside of BFB.

In common with many other companies BFB do make use of a Data Processor. This is Amazon Web Services (‘AWS’) for platform hosting, and app delivery.

AWS provides start-to-end information management, ensuring secure storage and secure disposal of data. They have the following accreditations:

ISO 27001 (Information Security Management System);
ISO 27017 (Cloud Security);
ISO 27018 (Cloud privacy);
SOC 1, 2, and 3 (security, availability, integrity, confidentiality and privacy);
BSI’s Common Cloud Computing Controls Catalogue.

Personal Data processed by AWS does not leave the UK.

How long do we keep personal data for

BFB will only retain your data for as long as is needed for the purpose of the research product or to make any improvements to Oshn where you have given feedback.

What rights do I have?

You have the right to request:

access to your personal data;
to erase personal data

If you wish to exercise a right please contact us at support@bfb-labs.com.

Complaints

We hope that there are no issues with your participation in the project however if you are dissatisfied with the way your personal data has been processed when using Oshn, please contact us.

Where your complaint relates to our processing of your personal data we will look into matters for you and reply to you within a reasonable time period.

After that, if you are still dissatisfied you have the right to complain to the Information Commissioner's Office (ICO). They can be contacted via this link.