A template. This policy is for an organization that receives recordings on a Walk4Me server. The organization that adopts it is the Receiving Organization and is responsible for it, alongside its own consent documents and approvals. It is not part of the Walk4Me app's Terms of Use, and the app's developer is not a party to it as the app's developer.
01Purpose and scope
This policy establishes general requirements for the recording, collection, submission, processing, and use of participant-generated digital content provided to a research institution, laboratory, or other authorized research organization (the "Receiving Organization"). It applies to video (with sound), photographs, audio, geolocation information, sensor recordings, associated metadata, and other digital content submitted through approved applications, recording devices, websites, or electronic data transfer systems, including the Walk4Me app and portal. This policy supplements applicable project-specific informed consent documents, research protocols, and other governing agreements, as well as any mobile application-specific privacy and content policies.
As the app's developer, the developer of the Walk4Me app is not the Receiving Organization and receives no recordings; they go only to the server the Receiving Organization runs. Where the developer is also part of the team that runs that server, they act for the Receiving Organization. See the app's Privacy Policy and Terms of Use.
02Personally identifiable information and device information
Participants acknowledge that submitted content may contain personally identifiable information (PII), including:
- Images, video, or audio recordings that identify individuals.
- Geolocation data, travel routes, and location histories.
- Dates, times, and locations of recorded activities.
- Device identifiers, application identifiers, account information, and associated metadata.
- Other information that may directly or indirectly identify participants or individuals appearing in recordings.
By submitting content, participants acknowledge that this information may be received, processed, and retained by the Receiving Organization for purposes authorized by applicable project-specific consent documents. Where necessary and authorized, the Receiving Organization may collect and retain device and account identifiers to authenticate submissions, verify data provenance, maintain data integrity, and document the source of submitted recordings. With Walk4Me these are Apple's anonymous identifier for the participant's Sign in with Apple (never the Apple ID email address or name), a random device ID created by the app, and the phone's model, iOS version and app build. Participants acknowledge that combinations of video, location, and device information may permit identification even when names and other direct identifiers are removed.
03Ownership and permission to use submitted content
Ownership, permitted uses, retention, and disposition of participant-generated content will be governed by applicable project-specific informed consent documents and other controlling agreements. Unless otherwise specified in those documents, submitted research data and records created, collected, or maintained by the Receiving Organization will be treated as records of the Receiving Organization, subject to applicable laws and institutional policies. This designation does not, by itself, transfer copyright or other independently held intellectual property rights.
By voluntarily submitting digital content, participants grant the Receiving Organization and its authorized personnel permission to receive, access, store, reproduce, process, analyze, and otherwise use the submitted content and associated information for purposes authorized by the applicable project-specific consent documents. This permission is understood to accompany submission and does not require separate authorization for individual processing or analytical activities falling within the scope of the applicable consent. To the extent participants retain intellectual property or other rights in submitted content, this permission constitutes a nonexclusive, royalty-free license for authorized research purposes. Nothing in this policy expands the scope of consent, overrides applicable legal rights, or authorizes uses or disclosures beyond those permitted by applicable project-specific consent documents.
Consent in the app. A setup QR code made on the portal may carry a consent text that the participant must accept on the phone before the app can be used with that code; the portal keeps a record of each answer, with the exact text shown. This feature is a tool for recording agreement. It does not replace or satisfy the informed consent process required by the applicable protocol unless that protocol and its approving body say so, and the wording of any such text is the Submitting Party's responsibility.
04Confidentiality and data protection
All submitted content will be treated as confidential and managed according to the protections, permissions, and limitations specified in applicable project-specific consent documents, research protocols, and governing policies. Access will be restricted to authorized research personnel and other approved recipients consistent with the applicable consent and regulatory requirements.
Submitted information will not be made publicly available or distributed outside authorized research activities except as permitted by applicable consent documents or required by law. The Receiving Organization will implement appropriate administrative, technical, and physical safeguards for the storage, processing, transfer, and retention of submitted content. How Walk4Me does this is described in the Data Privacy & Security Statement.
05Acceptable content and prohibited submissions
Participants must submit only content that is lawful, relevant to the authorized research activity, and consistent with instructions provided by the research team. Unless specifically authorized by an applicable research protocol, participants must not intentionally record or submit content containing:
- Nudity, sexually explicit or sexualized images, or sexual activity.
- Violence, abuse, exploitation, or graphic depictions of injury.
- Child sexual abuse material or other unlawful or exploitative content.
- Harassment, threats, hate speech, or discriminatory abuse.
- Illegal activities or content obtained through unlawful recording or surveillance.
- Material that infringes copyrights, privacy rights, or other legal rights.
- Recordings of individuals who have not provided legally required permission or consent.
- Malicious software, intentionally corrupted files, or material intended to compromise research systems.
Incidental recording of individuals, sensitive situations, or potentially objectionable content during otherwise authorized community-based research will be evaluated according to applicable project procedures. The Receiving Organization reserves the right to reject, restrict access to, quarantine, or remove submitted content that violates this policy, subject to applicable research record-retention requirements and institutional procedures.
06Participant responsibilities
Participants are responsible for complying with applicable laws and research instructions when creating and submitting content. Where the participant is a minor, a parent or legal guardian submits the content on the minor's behalf and makes the affirmations below. By submitting content, participants affirm, to the best of their knowledge, that:
- The content was recorded or obtained lawfully.
- They are authorized to submit the content for the approved research activity.
- They have followed applicable instructions concerning third-party privacy and consent.
- They have not intentionally submitted prohibited, materially misleading, manipulated, or unlawfully obtained content.
- They understand that submission may disclose personally identifiable information and device-associated metadata as described in this policy and applicable consent documents.
Participants should avoid recording sensitive activities or identifiable third parties when such recording is unnecessary for the research.
07Responsibility, liability, and indemnification
Participants are responsible for complying with applicable laws and research instructions when creating and submitting content. To the extent permitted by applicable law, participants agree to indemnify and hold harmless the Receiving Organization, its officers, employees, and agents against third-party claims, damages, and reasonable legal expenses arising directly from a participant's knowing unlawful conduct, intentional misconduct, or willful infringement of third-party rights in connection with submitted content. This provision does not release the Receiving Organization from responsibility for its own negligence or misconduct, waive participant legal rights, or supersede applicable human-subjects protections.
08Mandatory reporting and disclosure of unlawful activities
Members of the research team may be designated as mandated reporters under applicable California law, including requirements concerning suspected child abuse or neglect, elder or dependent adult abuse, and other legally reportable circumstances. Research personnel who are mandated reporters are legally obligated to report known or reasonably suspected abuse or other reportable circumstances to the appropriate authorities, consistent with applicable reporting requirements. In addition, research personnel may be required by institutional policy to report suspected unlawful activities, exploitation, threats to personal safety, or other serious misconduct discovered through submitted content.
Participants acknowledge that submitted video, audio, geolocation information, and other digital records may reveal activities or circumstances subject to mandatory reporting requirements. Confidentiality protections do not prevent disclosures that are required by applicable law. When legally required, the Receiving Organization or its personnel may disclose relevant information, including personally identifiable information, to appropriate authorities without obtaining additional participant permission. Any reporting or disclosure will be conducted in accordance with applicable law, institutional policies, and project-specific informed consent documents, including any applicable Certificates of Confidentiality or other legal restrictions. The Receiving Organization will limit disclosures to information necessary or legally required for the applicable reporting purpose.
09Policy enforcement
The Receiving Organization may reject submissions, restrict access, suspend submission privileges, or take other appropriate actions when submissions violate this policy. Potentially unlawful or harmful content may be referred to appropriate institutional authorities or external agencies when required by law or institutional policy, subject to applicable confidentiality protections. Any action affecting a participant's research involvement will be consistent with the applicable research protocol, informed consent documents, and institutional requirements.
10Withdrawal and removal
Participants may stop submitting content at any time. To have submitted content removed, participants contact the study investigator. In the Walk4Me app, Delete (Settings › Online) removes one person's QR code from the phone and from the participant's sign-in on the server, Delete all removes every one, and Delete account removes the sign-in itself; content already received is removed by the Receiving Organization on request, subject to applicable research record-retention requirements.
11Relationship to project-specific consent
This policy supplements, but does not replace, applicable informed consent documents, research protocols, and legally required authorizations. Where provisions conflict, the applicable project-specific consent documents and controlling legal or regulatory requirements will govern. Nothing in this policy authorizes additional uses, disclosures, or processing beyond those permitted by applicable project-specific consent documents.
12Acknowledgment and permission to process submitted content
By voluntarily submitting digital content to the Receiving Organization, participants acknowledge that their submission constitutes permission for the Receiving Organization to receive, store, process, analyze, and use the content and associated personally identifiable information in accordance with applicable project-specific informed consent documents and this policy. This acknowledgment does not replace informed consent, expand the scope of authorized research activities, or waive participant rights under applicable law.