Page content:
Table of Contents
Next steps
...
- Decide on the content of the Privacy Notice and cookie policy. Include Privacy Policy, Cookie Policy and Terms and Conditions.
- Review outstanding questions with Andrew Todd and Chris Brady.
- List all cookies in use on TIS in the content of the Privacy & by TIS application on Cookie Policy.
- To be discussed with Steven Pettengell (Unlicensed): Solution design with devs and UX/UI: Some level of design work may be required with regards to where and how it needs to be displayed with options to accept/decline for
- users who are logging in for the first time, .e.g. HEE admins, Trust users, Programme role users, TPD's
- trainees completing registration. We need to consider mobile design for trainees as well as desktop design for both trainees and non-trainees.
- Raise tickets and walk through with devPOs & Dev team.
Scope
...
- Trainee Accept/Decline Privacy Notice when logging in for the first time.
- Non-logged in trainee Accept/Decline Cookie Policy first visit to TIS site
- Logged in trainee view Privacy Notice via a hyperlink
- Non-logged in non-trainee Accept/Decline Privacy Notice first time
- Non-logged in non-trainee Accept/Decline Cookie Policy first visit to TIS site
- Logged in non-trainee view Privacy Notice via a hyperlinkPN1 - Trainee or any user visiting TIS site agrees to the use of cookies before continuing to use the site
- PN1 - HEE Admins/Trusts users/Programme role users/any users who had their account created on TIS by another admin to agree to the use of cookies before continuing to use the site.
- PN2 - Users should be able to access and read the Privacy Policy, Cookie Policy and Terms and Conditions via hyperlinks all the time, either when logged in or not logged in
- PN3 - Trainee Accepts/Declines Privacy Policy, Cookie Policy and Terms and Conditions when registering to use TIS.
Privacy & Cookie Policy Content
...
on HEE Domain
The TIS team discussed this with Chris Brady (Data Protection Lead) and Andrew Todd (Information Governance Lead) is currently working on a revised version of the Privacy Notice & Cookie Policy content for the HEE domain and will supply the signed off version when ready. However, for TIS we need an adapted version of this to be explicit, especially with regards to the specific cookies in use.
View file name Health Education England - Privacy and cookies - 2015-11-09 - TIS adapted version - v0.1.pdf height 250 View file name Health Education England - Privacy and cookies - 2015-11-09 - TIS adapted version - v0.1.docx height 250
...
. The below are the final versions currently published on HEE domain.
Privacy Policy content for HEE
https://www.hee.nhs.uk/about/privacy-notice
Cookie Policy content for HEE:
https://www.hee.nhs.uk/about/cookies
Terms and Conditions for HEE:
...
...
Privacy & Cookie Policy Content for TIS
For TIS we need an adapted version of the above to make explicit mention of how TIS controls or process data. We would also need to explicitly list specific cookies in use by the application and their purpose.
TIS uses Google Analytics, the following cookies are used out of the box:
...
https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
In addition to the
...
google analytics cookies, we also need to include the Keycloak session and TIS application cookies used.
...
Summary of Cookies used on TIS (Tbd - Devs to validate - Simon Meredith (Unlicensed)
...
)
Full details on the cookies set by Google Analytics are published on the Google website. Google also publishes a browser add-on to allow you to choose that information about your website visit is not sent to Google Analytics.
| Cookie name | Duration | Description | Purpose |
|---|---|---|---|
| Google analytics | |||
| _ _utma | 2 years from set/update | Used to distinguish users and sessions. The cookie is created when the javascript library executes and no existing _ _utma cookies existsexist. The cookie is updated every time data is sent to Google Analytics. | Tracks how many times (if any) you have visited the Trainee Information System (TIS) website. |
| _ _utmt | 10 minutes | Used to throttle request rate. | |
| _ _utmb | 30 minutes after your visit, or after 30 minutes of inactivity | Used to determine new sessions/visits. The cookie is created when the javascript library executes and no existing _ _utmb cookies exists. The cookie is updated every time data is sent to Google Analytics. | Tracks how long you have spent on the website. |
| _ _utmc | End of browser session | Not used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the _ _utmb cookie to determine whether the user was in a new session/visit. | |
| _ _utmd | 6 months after it was last set | Gives us information on how the site was reached (e.g. directly or a link, organic search or paid search) | |
| _ _utmz | 6 months after it was last set | Stores the traffic source or campaign that explains how the user reached your site. The cookie is created when the javascript library executes and is updated every time data is sent to Google Analytics. | Identifies where you've come from e.g. from a search engine or from another website |
| _ _utmv | 2 years from set/update | Used to store visitor-level custom variable data. This cookie is created when a developer uses the_setCustomVar method with a visitor level custom variable. This cookie was also used for the deprecated _setVar method. The cookie is updated every time data is sent to Google Analytics. | |
| Content experiments - cookie usage | |||
_ _utmx | 18 months | used to determine a user's inclusion in an experiementexperiment | |
| _ _utmxx | 18 months | Used to determine the expiry of experiements experiments a user has been included in | |
| Optimize 360 - cookie usage | |||
| _gaexp | Depends on the length of the experiment but typically 90 days. | Used to determine a user's inclusion in an experiment and the expiry of experiments a user has been included in. | |
| Keycloak and TIS application cookies | |||
| AUTH_SESSION_ID | session | Used for sticky connections to an individual node in the Keycloak cluster | https://github.com/keycloak/keycloak-documentation/blob/master/server_installation/topics/clustering/sticky-sessions.adoc |
| KEYCLOAK_IDENTITY | session | JWT representing the user identity. | |
| KEYCLOAK_SESSION | 12hr | Keycloak's session token | |
| KC_RESTART | session | JWT containing the redirect information to determin determine where a user should be returned to after logging in. | |
| mod_auth_openidc | |||
| mod_auth_openidc_state_ | session | Representation of the state of the current login | The "state" cookie is created when the user is redirected away to the OpenID Connect Provider for authentication. It is a cookie with a unique name (prefixed with a constant mod_auth_openidc_state_) that is tied to the state parameter that is sent in the authentication request. It is deleted when the user returns to the Apache server with an authentication response (indicating either success or failure) |
| mod_auth_openidc_session | session | mod_auth_openidc's session token | The "session" cookie is created after the user returns from the OpenID Connect provider with a successful authentication response (note that the state cookie is deleted at the same time) |
| TIS application <<Requires dev input>> | |||
| dashBoardState | session | User's current dashboard state for revalidation | Stores the user's preferences such as which colums columns to see, which sorting , filters and page are active |
| defaultLocale | 1 month | User's current locale | |
| session | session | Unique session identifier | The keycloak Keycloak session token |
| user | session | Cached user representation | |
Scenarios
...
- Rule: User should not be authenticated to TIS if they do not accept the Privacy Notice
- Error: Acceptance of the Privacy Notice is mandatory in order to access TIS functionality.
| Jira Legacy | ||||||
|---|---|---|---|---|---|---|
|
Who accepted/declined the Privacy Notice and when
Present audit log to all admins with view permissions
PN3 - Users should be able to access and read the Privacy and Cookie Policy via a hyperlink all the time
- User sees the Privacy and Policy link on TIS
- User clicks on the link and reads the content
- User can close the Privacy Notice (if in the form of a modal pop-up for e.g). and return back to where they were on TIS.
- Rule: The Privacy Notice & Cookie Policy should not require authenticated for a user to be able to access and read it.
| Jira Legacy | ||||||
|---|---|---|---|---|---|---|
|
Process Name | PN1 - | |||||||||
|---|---|---|---|---|---|---|---|---|---|---|
Trainee or any user agrees to the use of cookies before continuing to use the site | Comments | |||||||||
| Description | Users should be able to Accept/Decline Privacy Policy and Cookie Policy when logging in for the first time to consent to the use of cookies either on a mobile device or desktop before continuing to use the site. | Mobile design consideration to be discussed with Steve. | ||||||||
| Actors | Trainee | Pre-Conditions | User
| |||||||
| Pre-Conditions | User is not logged in | |||||||||
| Post-Conditions | System presents Privacy Notice & Cookie Policy with options to and accept/decline | Process Steps | alert the user of the use of cookies by the site with a link to view the full content of the cookies usage policy. | c.f. HEE Domain: This site uses cookies. By continuing to use this site or closing this message you agree to our use of cookies.
| ||||||
| Process Steps | N/A
| Alternative Process |
| |||||||
| Alternative Process | Navigating directly to the Privacy Policy or Cookie Policy pages to read full content. | |||||||||
| Rules |
| |||||||||
| JIRA Reference |
| |||||||||
| Audit Log | Who accepted/declined the Privacy Notice and when Present audit log to all admins with view permissions |
PN2 - Non-trainees Accept/Decline Privacy Notice and Cookie Policy when logging in for the first time.
- User navigates to TIS landing page (.../Admin/)
- User enters credentials and click on Login
- User presented with Privacy Notice
- User reads and Accept/Decline
- If user Accepts, they are successfully authenticated into TIS
- If user Declines, they are not authenticated into TIS and present relevant message with relevant support contact details
1. Do we need to audit the accept/decline of the Privacy Policy for users that have an account on TIS? 2. Do we need to audit the accept/decline of the Privacy Policy for users that do not have an account on TIS? If so, what do we need to record in this scenario? |
Process Name | PN2 - Users should be able to access and read the Privacy and Cookie Policy via a hyperlink all the time, either when logged in or not logged in | Comments | ||||||||
|---|---|---|---|---|---|---|---|---|---|---|
| Description | Users should be able to access and read the Privacy & Cookie Policy all the times | Note: This could be via a hyperlink on the header/footer of TIS site visible all the times. This link should not provide the options to accept/decline but just the content. | ||||||||
| Actors | Trainers, Educational Supervisors, Clinical Supervisors, TPD's, any users visiting or logged in to the site. | |||||||||
| Pre-Conditions | User is logged in or not logged in | |||||||||
| Post-Conditions | Privacy and Cookie Policy can be accessed and read | e.g HEE Domain has links for each in the footer always visible and accessible:
| ||||||||
| Process Steps |
| |||||||||
| Alternative Process | N/A | |||||||||
| Rules |
| |||||||||
| JIRA Reference |
| |||||||||
| Audit Log | N/A |
Process Name | PN3 - Trainee or any user consent to the Privacy Policy, Cookie Policy and Terms and Conditions when registering to use the trainees' application (draft) | Comments | ||||||||
|---|---|---|---|---|---|---|---|---|---|---|
| Description | Any user registering to use TIS should be able to consent/decline the Privacy Policy and Cookie Policy either on a mobile device or desktop for successful registration. | Mobile design consideration especially for the Trainees application. | ||||||||
| Actors | Trainees or any users registering to use TIS. | |||||||||
| Pre-Conditions | User is not logged and has not got an account on TIS with the username being supplied | |||||||||
| Post-Conditions | System alert the user of the use of cookies by the site with a link to view the full content of the cookies usage policy on the landing page. In order to complete registration, user presented with:
| c.f. HEE Domain: This site uses cookies. By continuing to use this site or closing this message you agree to our use of cookies.
| ||||||||
| Process Steps |
| This could be a unique link sent to a trainee as an invitation to complete their registration or alternative process to be discussed ahead of trainee app solution design. (To discuss with Matt Leech (Unlicensed) and devs) Do we need a separate Terms & Conditions page? | ||||||||
| Alternative Process | N/A | |||||||||
| Rules |
| |||||||||
| JIRA Reference |
| |||||||||
| Audit Log | 1. Do we need to audit the accept/decline of the Privacy Policy, Cookie Policy and Terms and conditions for users that have an account/incomplete account on TIS? 2. Do we need to audit the accept/decline of the Privacy Policy for users that do not have an account on TIS? If so, what do we need to record in this scenario? | To discuss the approach/solution design for trainees registration (Matt Leech (Unlicensed) and devs). |
UX/UI Designs (Tbd - Matt Leech (Unlicensed))
The designs below will need to be adjusted based on the scenarios and answers in the 'Questions and Assumptions' section.
TIS Trainee UI - Mobile - Legal Policy: Privacy and Cookies
https://hee-tis.atlassian.net/wiki/spaces/TISDEV/pages/232718339/TIS+Trainee+UI+-+Mobile+-+Legal+Policy+Privacy+and+Cookies
TIS Admin UI - Desktop - Legal Policy: Privacy & Cookies
https://hee-tis.atlassian.net/wiki/spaces/TISDEV/pages/239730689/TIS+Admin+UI+-+Desktop+-+Legal+Policy+Privacy+Cookies
Questions and Assumptions
| No. | Question or Assumption | Comments |
|---|---|---|
| 1. | Do we need to include a separate Terms and Conditions for the TIS site? If so what should be the content of this? Can we use the one here https://www.hee.nhs.uk/about/terms-conditions? | To discuss with Andrew Todd/Chris Brady AD: No. |
| 2. | For HEE Admins/Trust Users/Programme role users who already have an account on TIS and actively using TIS, should they be consenting to the use of
Or just agree to the use of cookies on their first login? | To discuss with Andrew Todd/Chris Brady AD: No needed.Covered by the corporate one, and ESR mandatory training. We are all part of HEE/NHS trusted users. |
| 3. | Could you provide the content of the Privacy Policy for TIS? We believe it would be an adapted version of https://www.hee.nhs.uk/about/privacy-notice | To discuss with Andrew Todd/Chris Brady AD: High level for TIS. Refer to ICO website. Link to corporate website on HEE domain. |
| 4. | We are currently reviewing the list of cookies to include on the Cookie Policy page for TIS. We believe it would be an adapted version of https://www.hee.nhs.uk/about/cookies. Could you review and confirm the other contents/changes as applicable for TIS? | To discuss with Andrew Todd/Chris Brady AD: Only include the ones we are clear about what they are doing and that not accepting them would affect usage of functionality on TIS. |
| 5. | The link on the cookie consent banner on HEE website takes you to the .../privacy-notice page rather than the .../about/cookies page. Is this correct? | To discuss with Andrew Todd/Chris Brady AD: This is an issue with the link. |
| 6. | PN3 - Trainee or any user consent to the Privacy Policy, Cookie Policy and Terms and Conditions when registering to use the trainees' application (draft)
| To discuss with Andrew Todd/Chris Brady AD: To trigger the ACCEPT and be able to fully register, they would need to accept. But they also need to decline. If they decline, they need to contact support. If a new cookie is introduced or content changes, they need to be able to read and accept them again, even if they are existing users. |
| 7. | HEE Records management policy - 5.6 Retention and disposal – there are consistent and documented retention and disposal procedures to include provision for permanent preservation of archival records - Is this up-to-date? We also have a piece of work on our roadmap/backlog to look at archiving and data retention on TIS. Should this work be a priority over Trainees being able to consent to Privacy and Cookie Policy or are we covered by the above records management policy? | To discuss with Andrew Todd/Chris Brady AD: Archiving can be treated separately and should not have a dependency on the trainees app. |