WELL121 Wellbeing Tracking App GDPR Statement V1 2018-02-16

WELL121 Wellbeing tracking app GDPR statement.


Wellbeing4business Ltd offers employee wellbeing surveys and online coaching to employees of organisations throughout the Uk. In this document, we will outline our compliance and commitment to GDPR.

WELL121 is a health-tracking app that links, through consent to an online health coach. APPLE and GOOGLE have approved the WELL121 APP, which is available to download freely. The app uses the world Reknown Nudge software which has been customised and branded by Wellbeing4business Ltd for distribution


WELL121 wellbeing tracking app can be:

  • Used by individuals opting to take part in a survey
  • Used by individuals who download the app
  • Used by employees referred to download the app by their organisation
  • Used by coaches to support clients

Participants could use the app/survey

  • As a standalone tracking tool
  • As part of a wellbeing initiative
  • As part of a wellbeing challenge
  • As part of a coaching course
  • As part of an event/fundraiser

Commitment statement

The EU General Data Protection Regulation (GDPR) is the most significant piece of European privacy legislation in the last twenty years. It replaces the 1995 EU Data Protection Directive (European Directive 95/46/EC), strengthening EU individuals’ rights over their data and creating a uniform data protection law across Europe. We will comply with the applicable GDPR as a data processor when they take effect on 25th May 2018. Working in conjunction with our clients, we will explore opportunities within our services offerings to assist our customers in meeting their GDPR obligations

Associated documents

  1. Privacy document
  2. Consent statements
  3. Supporting documentation from Armor data security

NUDGE Software

WELL 121 is provided by NUDGE, who have produced a wealth of regulations/documentation – see below

We have updated the Nudge policies and procedures to better align with the new General Data Protection Regulation (GDPR) that goes into effect today.

In general, we have added transparency to our published policies, especially regarding the way we collect and process personal data and the rights you have to request changes or deletions of that information. In addition to updating our Privacy Policy, we have also committed to maintaining a culture of compliance.

  • appointing a Data Protection Officer to lead this process
  • developing separate Cookies and Security Policies for added clarity
  • providing a list of third-party services we use that may process your data
  • certifying to the EU-US Privacy Shield Principles
  • and providing this Data Processing Amendment for our Customers

As always, you can manage your email preferences or unsubscribe using the links in the footer of this or any email we send.

If you have any questions or requests regarding these policy updates, please reply to this email or contact our support team at support@nudgecoach.com.


WELL121 wellbeing tracking app GDPR requirements

  • Notification of data breaches – When we are aware of a data breach of personal or sensitive personal data, we understand that we have a 72-hour window to notify the relevant supervisory authority of the breach. Additionally, we must notify data subjects of any breach that presents a high risk to their rights and freedoms.
    • Responsibility – Wellbeing4business Ltd
    • Security and rapid response – Nudge and Armor, SurveyMonkey
  • Ability to demonstrate compliance – This document outlines our understanding of the security requirements prescribed directly or indirectly by the regulated party to demonstrate compliance. We have aligned our data with the secure cloud controls that meet these specific requirements.
    • Refer to this document.


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