Legal, privacy and UK GDPR
Designed to keep children’s health reflections private by default.
This page describes the intended privacy model for Comic Journal during prototype
and pilot development. It should be reviewed by legal, clinical safety, and data
protection advisers before public launch.
Local
Device-first data
Current website
This informational website does not include accounts, forms, payment processing, or
patient data collection. It uses Google Analytics to understand website visits, and
the email call to action opens the visitor’s own email client. Analytics configuration,
consent, retention, and cookie use should be reviewed before wider public promotion.
Prototype data principle
Journal entries and child-created reflections should be stored on the local device
wherever possible. Device-local storage is the default design direction for personal
notes, preferences, and draft comic inputs.
LLM-assisted comic generation
If an LLM is used to generate comic content, prompts should be minimised, aggregated,
and anonymised before processing. Names, addresses, contact details, NHS numbers,
exact dates of birth, school names, or unnecessary clinical identifiers should not be
included.
Secure processing
Any processing that cannot happen on-device should happen in a secure environment with
access controls, encrypted transport, limited retention, and documented processors.
On-device generation is preferred where technically feasible.
Children and consent
The product is intended for children and health-related learning, so consent, parental
involvement, age-appropriate explanations, safeguarding, and clinical safety review are
required before live deployment.
UK GDPR approach
Before launch, Comic Journal should confirm controller details, lawful basis, special
category data handling, retention periods, data subject rights, international transfer
safeguards, and whether a Data Protection Impact Assessment is required.