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Privacy Policy Full

Contents

  1. ABOUT THIS POLICY

1.1 Purpose

1.2 Multi-layered approach

1.3 Currency

  1. HOW ST VINCENT’S UNIVERSITY HOSPITAL HANDLES YOUR PERSONAL INFORMATION

2.1 St Vincent’s University Hospital’s Legal Obligations

2.2 Terms used

2.3 Who does St Vincent’s University Hospital collect information from

2.4 What information does St Vincent’s University Hospital collect

2.5 How does St Vincent’s University Hospital store your information

2.6 How does St Vincent’s University Hospital use your information

2.7 Access to and correction of your personal information

2.8 Data quality

2.9 Data security

2.10 Cross border disclosure

  1. HOW TO CONTACT ST VINCENT’S UNIVERSITY HOSPITAL about privacy issues

3.1 Data Protection Officer

3.2 Complaints

  1. HOW ST VINCENT’S UNIVERSITY HOSPITAL HANDLES YOUR PERSONAL INFORMATION WHEN YOU VISIT OUR WEBSITE

4.1 Collection

4.2 Cookies

4.3 Links to third party websites

4.4 Use and disclosure

4.5 Data quality

4.6 Data security

4.7 Access and correction

  1. St Vincent’s University Hospital binding corporate rules

  1. ABOUT THIS POLICY

1.1 Purpose

St Vincent’s University Hospital (SVUH) is committed to ensuring the privacy and confidentiality of your personal information.

St Vincent’s University Hospital must comply with the General Data Protection Regulation (GDPR) and the Data Protection Act 1988.  The 1988 Act was amended by the Data Protection (Amendment) Act 2003. The 2003 Amendment Act brought our law into line with the EU Data Protection Directive 95/46/EC.

These legal frameworks ensures St Vincent’s University Hospital handles your personal information (including but not limited to patient health information).

The purpose of this Privacy Policy is to clearly communicate to you how St Vincent’s University Hospital handles your personal information. It will give you a better and more complete understanding of the type of personal information that St Vincent’s University Hospital holds about you and the way St Vincent’s University Hospital handles that information.

1.2 Multi-layered approach

This Privacy Policy has been developed in accordance with a ‘layered policy’. This means that it offers you the ability to obtain more or less detail about St Vincent’s University Hospital’s information handling practices – depending on how much you wish to read, what you need to know and how quickly you need to obtain the relevant information.

If you only require basic information about St Vincent’s University Hospital’s information handling practices, you can view our ‘condensed’ privacy policy. This is a summary of how St Vincent’s University Hospital collects, uses and discloses your personal information and how you can contact St Vincent’s University Hospital if you would like to access or request a correction to any personal information which St Vincent’s University Hospital holds about you.

If you require more detailed information about St Vincent’s University Hospital’s information handling practices, then you will need to read this document.

1.3 Currency

This Privacy Policy was last updated in May 2018 and may change from time to time. The most up-to-date copy will be published on the St Vincent’s University Hospital website or can be obtained by contacting us on the details set out at the end of this policy.

  1. HOW ST VINCENT’S UNIVERSITY HOSPITAL HANDLES YOUR PERSONAL INFORMATION

2.1 St Vincent’s University Hospital’s Legal Obligations

As mentioned in Part 1 of this Privacy Policy, St Vincent’s University Hospital is required to comply with the General Data Protection Regulation (GDPR) and the Data Protection Act 1988. As part of this we are regulated by the Office of Data Protection Commissioner (ODPC) and acts as St Vincent’s University Hospital’s Supervisory authority.

By letter: The Office of the Data Protection Commissioner, Canal House, Station Road, Portarlington, Co. Laois
By email: info@dataprotection.ie
Website: www.dataprotection.ie
By telephone: +353 (0761) 104 800

The ODPC is an independent public authority which regulates how St Vincent’s University Hospital may collect, use, disclose and store personal information and how individuals may access and correct personal information which St Vincent’s University Hospital holds about them.  For ease of reference, this Privacy Policy sets out St Vincent’s University Hospital’s position with respect to patient and other individuals’ personal information separately but we treat each group equally.

2.2 Terms used

In this Privacy Policy, we use the terms:

Personal data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person:

 “Data concerning health” means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status.

Primary purpose” means the specific function or activity for which the information is collected.  Any use or disclosure of the personal information for another purpose is known as the “secondary purpose”.

Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Pseudonymisation” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

“Personal data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

Binding corporate rules” means personal data protection policies which are adhered to by a controller or processor established on the territory of a Member State for transfers or a set of transfers of personal data to a controller or processor in one or more third countries within a group of undertakings, or group of enterprises engaged in a joint economic activity.

Supervisory authority” means an independent public authority which is established by a Member State pursuant to Article 51.

2.3 Who does St Vincent’s University Hospital collect information from?

This Privacy Policy applies to St Vincent’s University Hospital’s collection and use of personal information from patients, visitors, next-of-kin, nominated support persons, referring doctors, all staff both clinical and support services such as Accredited Health Professionals, contracted health professionals, trainees (including medical professionals including registrars, fellows and advanced trainees), approved researchers, students undertaking training placements in our facilities, contractors, suppliers, and service providers engaged by us, medical representatives attending our facilities and other individuals engaged by or providing services to St Vincent’s University Hospital.

2.3.1 Patients

In order to provide you with the required health care services St Vincent’s University Hospital will need to collect and use your personal information.

2.3.2 Other individuals

In order to enable St Vincent’s University Hospital to engage with you for the relevant primary purpose, St Vincent’s University Hospital may need to collect and use your personal information.  If you provide incomplete or inaccurate information to us or withhold personal information from us we may not be able to engage with you as required to meet that primary purpose.

2.4 What information does St Vincent’s University Hospital collect?

2.4.1 Patients

We collect personal information from you that is reasonably necessary to provide you with health care services and for administrative and internal business purposes related to your attendance at St Vincent’s University Hospital.

Often this may include collecting information about your health history, family history, your ethnic background or your current lifestyle to assist the health care team in diagnosing and treating your condition.

We will usually collect your health information directly from you.  Sometimes, we may need to collect information about you from a third party (such as a relative or another health service provider).

Your personal information which may include diagnostic data will be taken during your engagement with the hospital for the purpose of assisting or recording developments in your treatment.  This data may take many forms for example standard laboratory information, sleep studies, image information from areas such as Radiology and Endoscopy.   St Vincent’s University Hospital will, in all cases, manage your personal information contained in these clinical images in accordance with the General Data Protection Regulation and this Privacy Policy.

2.4.2 Other individuals

We collect personal information from you that is reasonably necessary to engage with you for the primary purpose, including the provision of services by St Vincent’s University Hospital, for St Vincent’s University Hospital’s functions or activities and for administrative and internal business purposes related to your dealings with St Vincent’s University Hospital.

We will usually collect your personal information directly from you.  Sometimes we may need to collect information about you from a third party; however, we will only do this where it is not reasonable or practical for us to collect this information directly from you.

2.5 How does St Vincent’s University Hospital store your information?

St Vincent’s University Hospital may store the personal information we collect from you in various forms.  St Vincent’s University Hospital will comply with the GDPR, and this Privacy Policy, in respect of your personal information in whatever form that information is stored by us.

2.5.1 Patients

Storage of personal information may be in physical (paper) form and may also include storage through electronic systems for storage of personal information (including clinical images taken for diagnostic or treatment purposes) on some diagnostic equipment where you have undergone a diagnostic procedure using such equipment in St Vincent’s University Hospital.

2.5.2 Other individuals

Personal information may be stored in various forms including electronic and/or paper systems in accordance with usual practices, and subject to the purposes of your engagement with St Vincent’s University Hospital.

2.6 How does St Vincent’s University Hospital use your information?

St Vincent’s University Hospital only uses your personal information for the primary purpose for which you have given the information to us, unless one of the following applies:

  • The secondary purpose is related (or for sensitive information, directly related) to the primary purpose for which you have given us the information and you would reasonably expect, or we have told you, that your information is usually disclosed for another purpose or to other individuals, organisations or agencies (see related secondary purposes set out below);
  • you have consented for us to use your information for another purpose, for example research;
  • St Vincent’s University Hospital is required or authorised by law to disclose your information for another purpose (see related secondary purposes set out below);
  • the disclosure of your information by St Vincent’s University Hospital will prevent or lessen a serious and/or imminent threat to somebody’s life, health or safety or to public health or public safety; or
  • the disclosure of your information by St Vincent’s University Hospital is reasonably necessary for the enforcement of a criminal law or a law imposing a penalty or sanction, or for the protection of public revenue.

St Vincent’s University Hospital may use or disclose your personal information as specified above via electronic processes, where available or relevant.

Related secondary purposes include:

The following is a list of examples of related secondary purposes for which St Vincent’s University Hospital may use your personal information, but it is not an exhaustive list.

Patient specific examples:

(a) Use among health professionals to provide your treatment

Modern health care practices mean that your treatment will be provided by a multi-disciplinary team of health professionals working together.

You may be referred for diagnostic tests such as pathology or radiology and our staff may consult with senior medical experts when determining your diagnosis or treatment. With developments in technology (e.g. telemedicine) our staff may consult with health professionals and medical experts, both public and private, located remotely, including outside St Vincent’s University Hospital, in relation to your diagnosis or treatment, including by sending health information and clinical images electronically.  Our staff may also refer you to other health service providers, both public and private, for further treatment during and following your admission (for example, to a physiotherapist or outpatient for community health services).  We may disclose your personal information to the relevant provider to the extent required for any such referral (including disclosing that information electronically).

Your personal information will only be disclosed to those health care workers involved in, or consulted in relation to, your treatment and associated administration and to the extent required to meet that purpose.

These health professionals will share your personal information as part of the process of providing your treatment.

We will only do this while maintaining confidentiality of this information and protecting your privacy in accordance with the law.

As part of your care, we may be required to disclose your information to third party medical suppliers for the purpose of ordering specific products or to enable appropriate follow up, for example, if you require prosthesis, certain pharmaceutical treatments or other medical implantable products as part of your treatment.

(b) Assessment for provision of health care services

St Vincent’s University Hospital may collect your personal information for the purpose of assessing your suitability for health care services at a St Vincent’s University Hospital. Where personal information is collected and you do not become a patient of the hospital, your personal information may be retained.  Where your assessment has been conducted at the request of your GP, St Vincent’s University Hospital will report the outcome of the assessment to that GP as it may be relevant to any ongoing treatment or care provided to you by them.

Where you undergo assessment or treatment by a third party provider (for example Radiotherapy in St Luke’s Hospital) during your admission to a St Vincent’s University Hospital for the purpose of transferring your care to that third party, St Vincent’s University Hospital may disclose your personal information to the third party provider for that purpose.

(c) Your local doctor

St Vincent’s University Hospital will usually send a discharge summary to your referring medical practitioner or nominated general practitioner following an admission. This is in accordance with international norms and long-standing medical practice and is intended to inform your doctor of information that may be relevant to any ongoing care or treatment provided by them. This discharge summary may be sent to your referring medical practitioner or general practitioner electronically.
If your nominated general practitioner has changed or your general practitioner’s details have changed following a previous admission, you must let us know.

(d) Other health service providers

If in the future you are being treated by a medical practitioner or health care facility that needs to have access to the health record of your treatment, we will provide a copy of your record to that medical practitioner or health care facility provide this request is processed in the correct manner.

We may provide information about your health records to another medical practitioner or health facility outside St Vincent’s University Hospital without your consent in the event of an emergency where your life or health is at risk.

(e) Students and trainees

St Vincent’s University Hospital supports the placement of students and trainees at St Vincent’s University Hospital and these students and trainees may have access to your personal information for the purpose of the placement.  Students and trainees on placement at St Vincent’s University Hospital are required to comply with the GDPR (or other relevant privacy legislation) and our Privacy Policy.

(f) Relatives, guardian, close friends or legal representative

We may provide information about your condition to your spouse or partner, parent, child, other relatives, close personal friends, guardians, or a person exercising your power of attorney under an enduring power of attorney or who you have appointed your enduring guardian, unless you tell us that you do not wish us to disclose your personal information to any such person.

(g) Other St Vincent’s Healthcare Group entities

St Vincent’s University Hospital may share your personal information amongst its other Group Hospital’s listed below.  For example, this may occur where you are transferred between any of St Vincent’s Healthcare Group hospitals or to coordinate your care.

  • St Vincent’s University Hospital
  • St Michael’s Hospital
  • St Vincent’s Private Hospital

(h) Other common uses

In order to provide the best possible environment in which to treat you, we may also use your personal information where necessary for:

  • activities such as quality assurance processes, accreditation, audits, risk and claims management, patient experience and satisfaction surveys and staff education and training;
  • invoicing, billing and account management, including storage of provider details on St Vincent’s University Hospital billing software;
  • the purpose of complying with any applicable laws – for example, in response to a subpoena or compulsory reporting to State authorities (for example, National Cancer Registry);
  • the purpose of sending you standard reminders, for example for appointments and follow-up care, by text message or email to the number or address which you have provided to us; and
  • we may anonymise or aggregate the personal information that we collect for the purpose of service management; monitoring, planning and development.
  • To identify patients that might be suitable for clinical trials/research. Any participation in a trial or research study will require your consent.

(i) Other uses with your consent

With your consent we may also use your information for other purposes such as including sharing your information with your insurance company and research.

Other non-patient specific examples:

(j) CCTV

St Vincent’s University Hospital does use camera surveillance systems (commonly referred to as CCTV) throughout our organisation for the purpose of maintaining the safety and security of its staff, patients, visitors and other attendees.  St Vincent’s University Hospital’s CCTV systems may, but will not always, collect and store personal information.  St Vincent’s University Hospital will comply with the GDPR and this Privacy Policy in respect of any personal information collected via its CCTV systems.

(k) Contractors under agreement

St Vincent’s University Hospital may provide, or allow access to, personal information to contractors engaged to provide professional services to St Vincent’s University Hospital’s (e.g. Information Communication Technology providers) or to contractors to whom aspects of our services are outsourced.  Where we outsource any of our services or hire contractors to perform professional services within our hospitals this will be done as part of a Service Provider Agreement which contains a Data sharing component that complies with the GDPR and where applicable our Privacy Policy.

(l) Application for accreditation by health professionals

St Vincent’s University Hospital collects personal information from health professionals seeking accreditation and submitting to the credentialing process.  Personal information provided by health professionals in this context is collected, used, stored and disclosed by St Vincent’s University Hospital for the purposes of fulfilling its obligations in connection with the accreditation sought.

(m) Job applications

St Vincent’s University Hospital collects personal information of job applicants who have responded to an advertised position for the primary purpose of assessing and (if successful) engaging applicants.  The purpose for which St Vincent’s University Hospital uses personal information of job applicants includes:

  • managing the individual’s employment, engagement or placement;
  • insurance purposes; and
  • ensuring that it holds relevant contact information.

St Vincent’s University Hospital may also store information provided by job applicants who were unsuccessful for the purposes of future recruitment or employment opportunities.

(n) Students / Trainees

St Vincent’s University Hospital collect personal information of students or trainees on placement for the primary purposes of providing the placement and facilitating assessment.  The purposes for which St Vincent’s University Hospital uses personal information of students or trainees include:

  • managing the individual’s placement;
  • ensuring the quality and safety of clinical care provided to St Vincent’s University Hospital patients;
  • insurance purposes;
  • ensuring that it holds relevant contact information; and
  • satisfying its legal obligations including obligations under any placement agreement.

St Vincent’s University Hospital may also store information provided by students or trainees following placement for the purpose of future recruitment or employment opportunities.

(o) Education and community engagement

St Vincent’s University Hospital may offer opportunities for health practitioners to participate in educational events or seminars for the purpose of continuing professional development or community engagement.  When you register for or attend an event, St Vincent’s University Hospital may collect your personal information for the purpose of providing the service and recording your attendance.

St Vincent’s University Hospital may disclose your personal information to third parties for the purpose of confirming your attendance at the event including the provision of attendance records or certification.

2.7 Access to and correction of your personal information

You have a right to have access to the personal information that we hold about you (for patients, this includes health information contained in your health record).  You can also request an amendment to personal information that we hold about you should you believe that it contains inaccurate information. The request will be reviewed with the relevant parties.

St Vincent’s University Hospital will allow access or make the requested changes unless there is a reason under the GDPR or other relevant law to refuse such access or refuse to make the requested changes.

If we do not agree to change your personal information in accordance with your request, we will permit you to make a statement of the requested changes and we will enclose this with your personal information.

Should you wish to obtain access to or request changes to your personal information held by St Vincent’s University Hospital please contact our Release of Information department at releaseofinformation@svhg.ie.

St Vincent’s University Hospital may recover reasonable costs associated with supplying this information to you.

2.8 Data quality

St Vincent’s University Hospital will take reasonable steps to ensure that your personal information which we may collect, use or disclose is accurate, complete and up-to-date.

2.9 Data security

St Vincent’s University Hospital will take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. We use technologies and processes such as access control procedures, network firewalls, encryption and physical security to protect your privacy.

2.10 Cross border disclosure

St Vincent’s University Hospital may enter into arrangements with third parties to store data we collect or to access the data to provide services (such as data processing), and such data may include personal information, outside of the EEA.  St Vincent’s University Hospital will take reasonable steps to ensure that the third parties do not breach the GDPR requirements.  The steps St Vincent’s University Hospital will take may include ensuring the third party is bound by privacy protection obligations which are the same (or substantially the same) as those which bind St Vincent’s University Hospital and requiring that the third party has information security measures in place which are of an acceptable standard and approved by St Vincent’s University Hospital.

  1. HOW TO CONTACT ST VINCENT’S UNIVERSITY HOSPITAL about privacy issues

3.1 Data Protection Officer

If you have questions or comments about this Privacy Policy, you can contact us:

By letter: Data Protection Officer, St Vincent’s University Hospital
Elm Park, Dublin 4
By email: dataprotection@st-vincents.ie
By telephone: (01) 221 4155

3.2 Complaints

If:

  1. St Vincent’s University Hospital does not agree to provide you with access to your personal information; or
  2. you have or a complaint about our information handling practices,

You can lodge a complaint with or contact our Data Protection Officer on the details above or directly with the Office of the

Data Commissioner. Full contact details can be found in section 2.4 or their website www.dataprotection.ie

  1. HOW ST VINCENT’S UNIVERSITY HOSPITAL HANDLES YOUR PERSONAL INFORMATION WHEN YOU VISIT OUR WEBSITE

This section of our Privacy Policy explains how we handle your personal information which is collected from our website: www.stvincents.ie  (collectively website hereafter).

4.1 Collection

When you use our website, we do not attempt to identify you as an individual user and we will not collect personal information about you unless you specifically provide this to us.

Sometimes, we may collect your personal information if you choose to provide this to us via an online form or by email, for example, if you:

  • complete your pre-admission form online;
  • upload personal information into a St Vincent’s University Hospital App;
  • submit a general enquiry via our contacts page;
  • register to receive share market reports;
  • register for an event or request information; or
  • send a written complaint or enquiry to our Privacy Officer.

4.2 Cookies

A “cookie” is a small bit of data our server sends to your browser that allows our server to identify and interact more effectively with your computer. Cookies do not identify individual users, but they do identify your ISP and your browser type.

This website uses temporary cookies. This means that upon closing your browser, the temporary cookie assigned to you will be destroyed and no personal information is maintained which will identify you at a later date.

Personal information such as your email address is not collected unless you provide it to us. We do not disclose domain names or aggregate information to third parties other than agents who assist us with this website and who are under obligations of confidentiality. You can configure your browser to accept or reject all cookies and to notify you when a cookie is used. We suggest that you refer to your browser instructions or help screens to learn more about these functions. However, please note that if you configure your browser so as not to receive any cookies, a certain level of functionality of the St Vincent’s University Hospital website and other websites may be lost.

4.3 Links to third party websites

We may create links to third party websites. We are not responsible for the content or privacy practices employed by websites that are linked from our website.

4.4 Use and disclosure

We will only use personal information collected via our website for the purposes for which you have given us this information.

We will not use or disclose your personal information to other organisations or anyone else unless:

    • you have consented for us to use or disclose your personal information for this purpose;
    • you would reasonably expect or we have told you (including via this policy) that your information is usually or may be used or disclosed to other organisations or persons for a related (or for sensitive information, a directly related purpose);
    • the use or disclosure is required or authorised by law;
    • the use or disclosure will prevent or lessen a serious and/or imminent threat to somebody’s life, health or safety or to public health or public safety; or
    • the disclosure is reasonably necessary for law enforcement functions or for the protection of public revenue.

If we receive your email address because you sent us an email message, the email will only be used or disclosed for the purpose for which you have provided and we will not add your email address to an emailing list or disclose this to anyone else unless you provide us with consent for this purpose.

4.5 Data quality

If we collect your personal information from our website, we will maintain and update your information as reasonably practical and necessary or when you advise us that your personal information has changed.

4.6 Data security

St Vincent’s University Hospital is committed to protecting the security of your personal information. We use technologies and processes such as access control procedures, network firewalls, encryption and physical security to protect the privacy of information. We will take all reasonable steps to prevent your information from loss, misuse or alteration.

Staff members associated with website maintenance have access to our website’s backend system. This is password protected. Our website service is also password protected.

4.7 Access and correction

If you wish to obtain information about how to access or correct your personal information collected via our website, please refer to Access and Correction at Item 2.7 of this document.

  1. St Vincent’s University Hospital binding corporate rules

Document Code Name Document Code Name
FCT-ICT-1 ICT Risk Assessment PPGN-ICT-25 McAfee Endpoint Encrypted Computer Usage
FCT-ORG-68 Data Protection Incident Report PPGN-ICT-28 SafeStick Encrypted Memory Stick Usage
PIL-ORG-19 Statement of Information Practices at SVUH PPGN-ICT-29 External Hospital Access
PPG ORG 181 Data Validation PPGN-ICT-30 ICT Access Policy
PPGN-ICT-1 Server Security and Computer PPGN-ICT-31 Core Application Change Management Policy
PPGN-ICT-5 Staff Remote Access PPGN-ICT-32 ICT Security Policy
PPGN-ICT-7 Audit Policy PPG-ORG-71 Record Retention Policy
PPGN-ICT-9 Workstation Security PPG-ORG-124 Password Policy
PPGN-ICT-11 Computer  Mobile Media Security PPG-ORG-125 Computer Usage Policy
PPGN-ICT-13 Wireless Communication Standard PPG-ORG-126 Data Protection and Information Sensitivity
PPGN-ICT-14 Third Party Remote Access Policy PPG-ORG-352 Data Protection Breach Management Policy
PPG-ORG-354 SVUH Data Protection Policy STAFF-ORG-17 Data Protection-It’s Everyones Responsibility –