Table of Contents
|2.||How do we collect information?|
|3.||What do we use information for?|
|4.||Who do we share information with?|
|5.||What type of information is collected?|
|6.||How long do we retain information?|
|7.||What are your rights?|
Blackrock Clinic (BRC) is committed to protecting all personal patient data collected during patient treatment.
This notice sets out the types of data we collect, and how we capture, use and protect all personal data collected and stored during the course of patient treatment. We also want you to be clear as to what rights you can invoke with respect to your information as a patent of BRC.
To this end, it is important that you read this Privacy Notice and understand our use of your personal data.
Please note, we reserve the right to update this Privacy Notice as required. This is the most recent version of this document.
1.1 Company Information
References to “BRC”, “us”, “our” and “we” refer to Blackrock Clinic Ireland Limited, and any associated companies from time to time. More information about BRC can be found within this web site.
All personal data we gather will be “processed” in accordance with all applicable data protection laws and principles, including the EU General Data Protection Regulation 2018 and the applicable Irish Data Protection Acts.
1.3 Queries and Complaints
If you require further information about the way your personal data will be used, or if you are unhappy with the way we have handled your personal data, and wish to contact us, please submit your concerns to: DPO@Blackrock-clinic.com
The DPO@Blackrock-clinic.com mailbox is managed by the BRC DPO function and all correspondence received will be addressed accordingly, including support from the designated BRC Data Protection Officer.
You have the right to lodge a complaint with the Office of the Data Protection Commissioner. To contact the Office of the Data Protection Commissioner, please use the following details:
Data Protection Commissioner
Canal House, Station Road, Portarlington, County Laois
Telephone: +353 (0)761 104 8000
Telephone: +353 (0)57 868 4800
LoCall Number: 1890 252 231
Fax: +353 (0)57 868 4757
Please note that we will take all appropriate steps to keep your personal data safe. In the unlikely event that we have a security breach, we will notify you without undue delay about the circumstances of the incident as required by our legal obligations.
2. How do we collect information?
We collect personal data to provide our services to you. This data may be collected directly by our staff, or by medical consultants, GPs, or other healthcare professionals who refer you to BRC, or who are involved in your treatment.
Sometimes we may request that other healthcare providers, such as other hospitals and pharmacies, provide us with data relating to you in order to improve the quality of our service to you.
In cases of emergency, we may receive your data from emergency services, such as the Gardai, the ambulance services or the fire brigade services. Once again, we receive this data purely for the purpose of ensuring the service we provide to you is of the highest standard.
3. What do we use information for?
We use your personal data so that we can provide past, current and future BRC patients with the highest quality of healthcare possible.
We work closely with selected partners who help us to provide you with services which we do not have the capability to provide independently.
Specifically, we may use the personal data we gather for any or all of the following purposes:
4. Who do we share information with?
There are various circumstances in which we may share personal data with other parties. Generally, this includes your representatives, our representatives, and some pre-advised third parties.
We may occasionally disclose your information to the following categories of companies or organisations to which we handover the responsibility to handle services on our behalf:
- Any medical consultants involved in your treatment at BRC,
- Any party which you have given us permission to speak with (family, friends or otherwise) regarding your treatment,
- Your next of kin, where you are not in a situation to grant us permission,
- GPs and other healthcare professionals involved in your treatment,
- Healthcare specialists whose opinion may aid us in effective medical diagnosis and / or treatment,
- Healthcare providers engaged to assist with your treatment (certain providers have facilities which assist us in providing you with efficient and effective treatment),
- Your health insurer (or their representative) or any other third-party provider with whom you have an agreement to cover the cost of your treatment,
- Billing agencies engaged by your consultant or other healthcare professionals involved in your treatment,
- Legal representatives, as necessary,
- Statutory bodies and health boards as required by EU and Irish law.
We take steps to ensure that any third-party partners who handle your information comply with data protection legislation and protect your information to the same extent that we do. We only disclose personal information which is necessary for them to provide the service they are undertaking on our behalf. We will aim to anonymise your information or use aggregated non-specific data sets where possible.
On occasion we may transmit your data outside of the European Economic Area. In such circumstances. we will ensure that the data is transferred in a secure manner, in accordance with data protection legislation and with your consent.
If you would like more information about the relevant safeguards in place for the transfer of personal data to countries or companies outside the European Economic Area, please contact us using the details outlined in Section 1. above.
5. What type of information is collected?
As a healthcare provider we need to collect many categories of personal data about our patients, the majority of which is highly sensitive in nature.
While the type of personal data we process may change occasionally, we believe it is important that you are aware of the types of personal data we gather and use. The following table is a non-exhaustive list of the categories and types of personal data we use to perform our duties.
Please note that the information listed under one category may be used for the performance of a task, or in relation to activities listed under another heading, or as outlined in Section 3. above.
6. How long do we retain information?
We only keep your information for as long as is necessary for the purpose for which it was originally obtained. Please note that the retention periods for medical information are defined on a case-by-case basis as required for the provision of healthcare to the patient. In this regard, retention periods for medical information will be defined based on the individual circumstance of each patient. We will take all necessary steps to ensure that the privacy of information is maintained upon disposal.
7. What are your rights?
You have a number of rights when it comes to your personal data. On receipt of a valid request to invoke one of your rights, we will do our best to adhere to your request as promptly as reasonably possible, however, restrictions may apply in certain situations.
Where do I send requests?
Please send all requests to the contact details provided in Section 1., with as much detail as possible regarding your requirements to enable us to deal with your request efficiently. To answer your request, we may ask you to provide identification for verification purposes.
How long will a request take to complete?
Upon receipt of a request, we will have 30 days to provide a response, with an extension of two further months if required. If we require more time to deal with your request, we will notify you of the delay, and of the factors responsible for the delay, within 30 days of the receipt of your request. If we refuse your request, we will notify you within 30 days of the receipt of the request accompanied by the reason for refusal.
You are entitled to contact the Office of the Data Protection Commissioner if we refuse your request.
How much does it cost to submit a request?
We will not charge a fee for any requests, provided we do not consider them to be unjustified or excessive. If we do consider these to be unjustified or excessive, we may charge a reasonable fee (also applicable for multiple copies) or refuse the request.
Right of Access
You have a right to know what personal data we hold on you, why we hold the data, and how we are using the data.
When submitting your request, please provide us with information to help us verify your identity and as much detail as possible to help us identify the information you wish to access (i.e. date range, subject of the request).
Identity verification will require a copy of your photographic ID, as well as the provision of three unique identifying factors from your medical record.
If the request is submitted by a third party (such as a solicitor) on your behalf, the request will be required to include written authorisation from you for the provision of a specific data to the third party.
Right to Rectification
You have a right to request that the personal data held in relation to you is up to date and accurate.
Where information is inaccurate or incomplete, we encourage you to contact us to have this information rectified. Upon receipt of your request, we will ensure that the personal data is rectified and as up to date as is reasonably possible.
Right to Erasure
You have the right to seek the erasure of personal data relating to you in the following circumstances:
- The personal data is no longer required for the purposes for which it was obtained.
- Where the use of the data is only lawful on the basis of consent, you withdraw consent to the processing and no other lawful basis exists.
- The personal data is being used unlawfully.
- You object to the use of your personal data and there are no overriding legitimate grounds for the use of the data.
- Your personal data requires deletion in line with legal requirements.
However, we will be unable to fulfill an erasure request if the personal data is required for the treatment of an active patient. We will also not be able to delete data which is being held in the public interest, such as for protecting against cross-border threats or ensuring high standards of quality and safety of healthcare.
Please be aware that in certain circumstances we may need to retain some information to ensure your preferences are respected in the completion of our duties. For example, we cannot erase all information about you where you have also asked us not to send you marketing material. Otherwise, your preference not to receive marketing material would be erased.
Right to Restriction
You have the right to restrict the extent for which your personal data is being used by us in circumstances where:
- You believe the personal data is not accurate (restriction period will exist until we update your information).
- The processing of the personal data is unlawful but you wish to restrict the use of the data rather than erase it.
- Where the personal data is no longer required by us but you require the retention of the data for the establishment, exercise, or defence of a legal claim.
- You have a pending objection to the future use of your personal data.
When the use of your data has been restricted, your personal data will only be further used: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of other people; or for reasons important to public interest, such as for the protecting against cross-border threats or ensuring high standards of quality and safety of health care.
We will contact you to confirm where the request for restriction is fulfilled and will only lift the restriction after we have informed you that we are doing so.
Right to Data Portability
You have the right to the provision of all personal data, which you provided to us, provided to you in a structured, commonly used and machine-readable format where:
- The lawfulness of the use of your personal data by us is reliant on the basis of a contract.
- The lawfulness of the use of your personal data by us is reliant on the provision of your consent.
- The data is being utilised by fully automated means.
You may also request that we send this personal data to another legal entity where technically feasible.
We will only refuse such a request if the data being requested may adversely affect the rights and freedoms of others.
Right to Object
You have the right to object to the further use of your personal data where:
- The lawfulness of the use of your personal data by us is reliant on the basis of our legitimate interests.
- Where the data is non-sensitive, and being used for reasons in the public interest.
- Where the data is being used for direct marketing purposes.
If you wish to object to the use of your data, please contact us with your request. We will then stop using the data or personal data unless it is required for legal proceedings.
Right not to be subject to Automated Decision Making Profiling
You have a right not to be subject to a decision based solely on automated processing or profiling, where such decisions would have a legal effect or significant impact on you.
Currently, we do not employ any systems which use automated decision making or profiling on data relating to our patients.
Where we (or one of our third-party processors) use profiling, which produces legal effects for you or otherwise significantly affects you, you will have the right to object to such processing.