Privacy notice for the Intercept Health screening

1. Who we are

Intercept Health is a product of beale horton Health (full registered entity name and company type), a health system operating in Ghana. Its registered office is at registered office address and its operational base is in Accra, Ghana.

For the purposes of the Data Protection Act, 2012 (Act 843) we are the data controller for the personal data described in this notice. Our registration with the Data Protection Commission of Ghana is registration number and status — confirm before publishing.

Where a screening programme is run for an employer, school or community partner, that organisation may also be a controller for its own records of who took part. Confirm the controller / joint-controller position for sponsored programmes.

2. What this notice covers

This notice covers the Intercept Health screening conversation you have with us on WhatsApp, the Exposure Health Score it produces, and the follow-up we send you about it.

It sits alongside the main beale horton Health privacy policy, which covers care delivered at our locations and everything else we do. Where the two differ on the Intercept Health screening, this notice applies. Where this notice is silent, the main policy applies.

It does not cover WhatsApp itself, which is operated by Meta under its own terms — see section 8 — or the separate privacy practices of partner clinics, sponsoring employers and schools acting as controllers in their own right.

3. How the screening works

The whole point of Intercept Health is that it reaches you on WhatsApp, in about three minutes, with no clinic visit. In practice that means:

1. You start the conversationYou message our WhatsApp number, or you reply to an invitation sent through your employer, school or community partner. We do not message you cold.
2. We tell you what we are about to ask, and you consentBefore any health question, the bot explains what the screening is for and asks you to confirm you agree. If you do not agree, the conversation stops there.
3. The bot asks a short set of questionsAbout the work you do and the conditions you do it in, plus the standard health questions a clinician would ask — see section 4.
4. We calculate your Exposure Health ScoreA number from 1 to 100 with a colour band. Higher is better.
5. We send it back to you on WhatsAppWith plain-language next steps. If the score warrants it, we offer to route you to a clinician.
6. We check in laterOnly if you agreed to it. Your score can be updated as your work and life conditions change.

4. What we collect

Your identifiers

• Your WhatsApp phone number — this is how the screening reaches you, so it is unavoidable.
• The name or nickname you give the bot, if you give one.
• The programme, employer, school or partner you came through, where you were invited by one.
• A record of the consent you gave, when you gave it, and any consent you later withdraw.

Your answers about exposure

These feed the exposure side of the score. They cover the five exposure families Intercept Health measures:

• Chemicals — pesticides, solvents, industrial chemicals.
• Metals — lead, cadmium, welding fumes.
• Dust and smoke — silica, biomass smoke, organic dust, traffic fumes.
• Heat — repeated heat strain and sun exposure.
• Labour and noise — physical demands of the work and loud equipment.

Alongside these we ask about your typical shift length and the kind of work you do.

Your answers about conventional health risk

These feed the clinical side of the score: age, sex, smoking status, weight, any history of high blood pressure, relevant family history, and the symptoms you currently have. Several of these questions are drawn from validated instruments — the ATS respiratory questionnaire, the Nordic skin questionnaire, the Q16 neurotoxicity scale and the Agricultural Health Study.

Conversation and technical data

• The messages you send the bot and the messages it sends you, including free-text replies.
• Delivery and read status, timestamps, and the WhatsApp message identifiers needed to run the conversation.
• The scores we calculated for you and when.

We do not ask for your location, and the screening does not read your contacts, photos, files or any other WhatsApp conversation. What our messaging provider records at the network level is technical metadata retained by the WhatsApp Business API provider — confirm with the provider's data processing agreement.

5. Why we process it

We use what you tell us to:

• calculate and send you your Exposure Health Score;
• flag exposure-related health risk early and route you to a clinician where it is warranted;
• follow up with you about your score, where you agreed to that;
• run screening and prevention programmes sponsored by employers, schools and community partners;
• meet legal, regulatory and public-health obligations in Ghana;
• improve the screening itself, and support research where you have agreed to it or where the data has been properly de-identified.

Act 843 requires that processing be lawful, limited to a stated purpose, and carried out with your knowledge. For the Intercept Health screening we rely on your consent, given in the conversation before any health question is asked. We may also process data where it is necessary to protect your vital interests, to comply with a legal obligation, or to carry out a task in the public interest.

We do not use your answers to sell you anything, and we do not use them for advertising or profiling unrelated to your health.

6. Health data and consent

Almost everything the screening asks is special personal data under Act 843 — information about your physical health, and about conditions of work that bear on it. Special personal data attracts additional protection.

We process it only where you have given explicit consent in the conversation, or where the Act otherwise permits it — for example to protect your vital interests in an emergency, or for medical purposes carried out by a health professional under a duty of confidentiality.

7. Your score, and what it is not

The Exposure Health Score combines two inputs into a single number from 1 to 100, where higher is better: an exposure burden score, which carries no demographic factors at all, and a conventional risk score, which carries the standard clinical ones. Neither input can mathematically cancel the other out — a clean conventional profile cannot mask a high exposure burden.

You receive a single number and a colour band:

• GreenNothing in your answers calls for action now.
• AmberSomething is worth a closer look. We offer next steps.
• RedWe offer to route you to a clinician.

The scoring method is built from validated instruments and re-checked every year by an independent board of doctors and scientists. Your answers are not used to make an automated decision that has a legal or similarly significant effect on you; under Act 843 you can in any case ask that decisions significantly affecting you are not based solely on automated processing.

8. WhatsApp, Meta and your phone

The screening runs inside WhatsApp, which is operated by Meta. That has consequences worth being plain about:

• Message content between you and us is protected by WhatsApp's end-to-end encryption in transit, but once a message reaches our system it is readable by us, because the bot has to read your answers to score them.
• Meta processes message delivery, and handles metadata such as your phone number and when messages were sent, under its own terms and privacy policy. We do not control that processing and this notice does not extend to it.
• The conversation stays in the WhatsApp app on your phone until you delete it there. Deleting your data from our systems does not delete the chat history on your own device — you have to do that yourself.
• If someone else can open WhatsApp on your phone, they can read the conversation. If that is a risk for you, delete the chat after you get your score.

We reach WhatsApp through a business messaging provider acting as our processor under contract. That provider is name of the WhatsApp Business Solution Provider and the country its infrastructure sits in.

9. Who sees your answers

We share personal data only where it is necessary, and only with:

• Clinicians and care teams in the beale horton network, where your score routes you to care. A clinician sees more than you do: both component scores, the exposure drivers behind them, the body systems affected and the differential considerations — because that is what makes the referral useful.
• Service providers processing data on our behalf under contract — hosting, messaging and IT. The current list is list of data processors and sub-processors.
• Regulators and public authorities where we are legally required to report, for example notifiable disease reporting.

We do not sell personal data, and we do not share it for third-party advertising.

10. Research and de-identified data

Understanding what work does to people's bodies is the reason Intercept Health exists, and research is part of that. Where you have agreed, or where your data has been de-identified so that it can no longer be linked back to you, we may use screening data to study exposure and disease and to improve the score itself.

De-identification means removing your phone number, name and any other direct identifier before the data is used. Our de-identification standard, and whether any data is ever shared with external research partners in identifiable form, is de-identification method, re-identification safeguards, and the named research partners and their agreements.

Declining research use does not affect your score, your follow-up or your access to care.

11. If you also wear an ORTON badge

Some people who take the screening are also issued an ORTON exposure badge, which reads wear time and heat exposure passively in the background and syncs when it is back on a network. Where you have been issued one, those readings are associated with you and feed the same score.

The specific measurements the badge collects, how often it samples, and whether any location data is recorded are exact sensor data fields, sampling frequency and whether location is captured. Everything else in this notice — sharing, retention, your rights — applies to badge data in the same way it applies to your answers.

12. Processing outside Ghana

Some of the systems behind the screening — WhatsApp itself, our messaging provider and our hosting — may store or process data outside Ghana. Act 843 places conditions on processing personal data originating in Ghana in a foreign jurisdiction. The countries involved, and the safeguards applied to each, are destination countries and the legal basis and safeguards for each transfer.

13. How long we keep it

We keep personal data only as long as necessary for the purpose it was collected, or as long as the law requires. Where a screening leads to clinical care, the resulting record becomes a clinical record and is subject to statutory minimum retention periods in Ghana, which override your deletion request for that record.

14. How we protect it

We are required to take reasonable steps to protect personal data against loss, damage and unauthorised access. Our measures include access controls limiting who can view screening data, staff confidentiality obligations and training, encryption of data in transit, and separation between the identifiers that reach the bot and the data used for analysis. Further detail, including encryption at rest and our breach-response process, is security control summary and incident response process.

No system is completely secure. If a breach occurs that is likely to affect you, we will notify you and the Data Protection Commission as required.

15. Stopping the bot and deleting your data

You are in control of the conversation at all times. At any point you can message the bot:

• STOP — we stop messaging you. No further screening questions, reminders or check-ins.
• DELETE — we delete the personal data we hold from your screening, except anything we are legally required to keep, and tell you what was kept and why.
• MY DATA — we send you a copy of what we hold about you.

The exact keywords the bot recognises, and how quickly each request is actioned, are confirm the live keyword set against what the bot implements, and the turnaround for each. You can always make the same requests by email using the details in section 19, and blocking our number in WhatsApp will stop messages reaching you immediately.

Withdrawing consent or deleting your data does not affect your access to care at any beale horton location.

16. Your rights under Act 843

Subject to the conditions in the Act, you have the right to:

Be informed

Know whether we hold personal data about you, and why.

Access your data

Ask for a copy of the personal data we hold about you, including your screening answers and score history.

Correction and deletion

Ask us to correct data that is inaccurate — including an answer you gave the bot by mistake — or to delete or block data that is inaccurate, irrelevant, excessive, or held without a lawful basis.

Object to processing

Object to processing that is likely to cause you unwarranted damage or distress.

Stop direct marketing

Ask us to stop using your data to send you marketing.

Automated decisions

Ask that decisions significantly affecting you are not based solely on automated processing.

Withdraw consent

Withdraw consent you have given, without affecting your access to care.

To exercise any of these rights, message the bot as described above or contact us using the details below. We will respond within response time commitment — confirm against the statutory period. We may ask you to verify your identity first, which for a WhatsApp screening usually means confirming the request from the same number. There is no charge for making a request in most cases.

17. Children and young people

Where the screening is offered to a child, or run through a school, we process the child's data with the consent of a parent or guardian, except where the law allows otherwise. Because WhatsApp's own terms set a minimum age for using the service, a young person below that age cannot take the screening on their own account. Our approach to the age at which a young person may consent for themselves is age of self-consent applied, and how school-programme consent is obtained and recorded.

18. Changes to this notice

We may update this notice. The date at the top shows when it was last changed. Where a change materially affects how we use your data, we will take reasonable steps to tell you directly — including, where appropriate, a message on WhatsApp.

19. Complaints and contact

If you have a question about this notice, or want to exercise your rights, contact us first — we would rather resolve it directly.

You also have the right to complain to Ghana's supervisory authority, the Data Protection Commission, which can investigate how we handle personal data. Its current contact details are Data Protection Commission address, telephone and website — verify before publishing.