Wellness privacy assessment
The short version. Wellness check-ins ask adult players five quick questions a day about how they feel. That is health data, so it is off until a head coach turns it on, each player decides for themselves, only two people read the answers, and everything is deleted after 90 days or the moment a player stops.
This is the data protection impact assessment (DPIA, GDPR Article 35) for Hashmark's wellness check-ins. Vantry LLC, which runs Hashmark, wrote it for the clubs and teams that use the feature. When a head coach or team owner turns wellness on, they accept it for their team. A club may adapt it to its own situation.
1. Who is responsible
- The club or team decides to use wellness check-ins and why. It is the "controller".
- Vantry LLC (Hashmark, 2524 Van Beek Road, Green Bay, WI 54311, USA) stores and processes the answers for the team. It is the "processor", under section 14 of our terms.
- Questions: the team's head coach first, or support@usehashmark.com.
2. What it is for
To help the head coach and the team's trainer adjust practice and check in with a player who slept badly, is very sore, is stressed or is in pain, before it turns into an injury. It is not a medical tool. It makes no diagnosis, keeps no medical records and decides nothing on its own.
3. What is collected
| Asked | Answer |
|---|---|
| Sleep | 1 to 5 (very poor to very restful) |
| Soreness | 1 to 5 (none to very sore) |
| Energy | 1 to 5 (very low to very high) |
| Stress | 1 to 5 (calm to very stressed) |
| A pain or a small injury | Yes or no |
With each answer: the date, the time it was sent, the player's account and the team. Each player's yes is kept with its date and the version of this assessment.
Never collected: written notes, where it hurts, diagnoses, treatment, medication, location, wearable or GPS data.
4. Who can take part, and on what basis
- Adult players only (18 or older). Each player confirms it when saying yes. A player linked to a parent in Hashmark (a minor) can't take part.
- Explicit consent (GDPR Articles 6(1)(a) and 9(2)(a)). Saying yes is a separate step on the player's own phone. It is not part of joining the team.
- Taking it back is one tap ("Stop taking part"), and every answer the player gave on that team is deleted at once.
5. Who sees the answers
| Who | Sees |
|---|---|
| The player | Their own answers for the last 28 days |
| The team's head coach | The answers of players who took part, with a readiness score and a red mark for low readiness or pain |
| One trainer the head coach names | The same as the head coach. With no trainer named, only the head coach. |
| Everyone else | Nothing: coordinators, position coaches, statisticians, the broadcaster, team owners who aren't the head coach, the club office, parents and other players |
The database itself checks these rules on every request; they don't depend on what the app chooses to show. Nobody is listed, counted or reminded for not answering.
6. How long it is kept
- 90 days, then deleted automatically every night.
- At once when the player stops taking part, when the head coach turns wellness off (every answer on the team), or when the player deletes their account.
7. Where it is kept and how it is protected
- Stored with Supabase in Ireland (EU), on Amazon Web Services, encrypted in transit (HTTPS) and at rest.
- The answers can't be read directly from the app's side. They are only reachable through server functions that check the reader's role each time.
- Vantry LLC is a US company. Its staff can reach the database to keep the service running, and they open wellness answers only to answer a request from the club or the player. Transfers to the US are covered by the European Commission's Standard Contractual Clauses.
- If a breach touches wellness answers, Vantry LLC tells the club without delay so it can tell the players and the authority as the law requires.
8. Is it necessary and proportionate?
- As little as possible: five fixed answers, no free text, nothing that names a condition.
- Off by default, team by team. A team that doesn't want it never collects anything.
- The shortest useful time: 90 days covers a training block and its trends.
- Two readers: the people who plan the training load and talk to the player about it.
- No pressure built in: no reminders, no "who hasn't answered" list, nothing ranks players for answering.
9. Risks and what limits them
| Risk to the player | What limits it | What's left |
|---|---|---|
| Feeling forced to take part, because the coach decides who plays | Off by default; each player decides alone; no reminders or list of who hasn't answered; the club commits never to use answers, or not answering, to pick or punish anyone (section 10) | Low |
| Health information seen by people who shouldn't | Two readers only, checked by the database; parents, the office and teammates see nothing | Low |
| A leak or breach | EU hosting, encryption, no direct table access, minimal data, 90 days | Low |
| A minor's health data | 18 or older confirmed by the player; players linked to a parent are blocked; the club knows its players' ages | Low |
| Answers used to drop a player or in a contract talk | The score only prompts a conversation; Hashmark decides nothing; the club's commitment (section 10) | Low, and in the club's hands |
| Kept longer than needed | Nightly deletion after 90 days; deletion when a player stops, wellness is turned off or an account is deleted | Low |
10. What the club commits to
By turning wellness on, the head coach or owner accepts for the team that:
- Answers are used only to plan training and check in with players.
- Taking part is optional. Answers, or not answering, are never used to select, drop, fine or rank a player.
- The trainer they name keeps the answers confidential.
- Players are told the feature is optional before they're asked about it.
- The club answers players' requests (see, correct, delete) with Hashmark's help.
11. The player's rights
A player can see their own answers in Hashmark, change today's answer, stop and delete everything with one tap, and ask the club or support@usehashmark.com for a full copy. They can also complain to their data protection authority (in France, the CNIL).
12. Conclusion
With these measures, the remaining risk to players is low, so no prior consultation with a data protection authority is needed (GDPR Article 36). This assessment is reviewed every season and whenever the wellness check-ins change. A change that matters gets a new version, and head coaches accept it again.