Privacy Notice

Last Updated April 2023

Introduction

This Privacy Notice sets out the basis upon which we collect, use, store and disclose personal data collected from you and/or held about you, as well as your rights in relation to that data. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Peamount Healthcare (“us”, “we” or “our”) is committed to protecting and respecting your privacy. This Privacy Notice sets out the basis on which any personal data we collect from you or that you provide to us (“Data”) will be processed by us.

In this Privacy Notice, references to “you” means the person whose Data we collect, use and process.

We will use your Data only for the purposes and in the manner set forth below, which describes the steps we take to ensure the processing of your Data is in compliance with European Union Law including (EU) 2016/679 (known as the General Data Protection Regulation or GDPR) and any subsequent amendments (collectively referred to as “Data Protection Legislation”).

Identity of the Data Controller

For the purposes of Data Protection Legislation, the Data Controller is Peamount Healthcare and can be contacted at info@peamount.ie. You can also contact us at the following address

Address: Peamount Road, Newcastle, County Dublin, Ireland

Phone: 01 6010300

What personal information may we collect from you?

When we refer to personal data in this policy, we mean information that can or has the potential to identify you as an individual.

We may hold and use personal data about you as a resident, patient or in any other capacity. Depending on the services you receive from us, this may include special category personal data such as information relating to your health

Personal data we collect from you may include the following:

Information that you give us when you enquire or become a patient of ours such as your full name, address, contact details (including email address and phone number), date of birth, gender, age
Health reports including any allergies or health conditions
Results of x-rays, scans, blood tests
Information you give us when you make a payment to us, such as financial or credit card information.
Name and contact details (including phone number) of your next of kin or relatives.

Notes and reports about your health and any treatment and care you have received and/or need, including information relating to clinic and hospital visits and medicines administered.
Information about complaints and incidents.
Images stored on the CCTV systems in use at our facilities for medical, safety and security purposes

We collect your Data from limited sources. The table below sets out the different purposes for the data that we collect. Please note that if you do not provide us with your contact information, we will not be able to provide you with any information you request.

Purpose	Examples	Legal Basis of processing	Retention
Direct Care and Administrative Purpose	· Delivery of care for the services we offer 1. Rehabilitation Services, this includes Services for older people and those with respiratory conditions 2. Residential Services which include For people with a neurological disability, people with an intellectual disability and older people 3. Community Services Which include day care for older people, an education centre and the provision of a range of diagnostic tests to the community · Sharing between individuals involved in care · Waiting list management	6(1)(e) ‘…for the performance of a task carried out in the public interest or in the exercise of official authority…’ 9(2)(h) ‘…medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems…’	Minimum of 7 years
Regulatory and public health functions	· Monitor health status to identify community health problems · Preparing for and responding to public health emergencies	6(1)(c) ‘…necessary for compliance with a legal obligation 9(2)(j) ‘ …necessary for reasons of public interest in the area of public health…or ensuring high standards of quality and safety of health care and of medicinal products or medical devices…	Minimum of 7 years
Billing and payment processing	· To complete a financial transaction related to medical treatment or services provided by the hospital.	Article 6(1)(b) is the legal basis for processing personal data that is necessary for the performance of a contract.	7 years in accordance with irish law
CCTV	· Monitor and manage access to the hospital, · Ensure the safety and security of patients, staff, and visitors · Prevent and investigate theft, vandalism, and other forms of property damage. · Monitor and respond to emergency situations, such as fires, floods, and medical emergencies.	Article 6(1)(f) provides a legal basis for processing personal data when it is necessary for the purposes of the legitimate interests pursued by the data controller	30 days (TBC)

How We May Share Your Personal Data

We will share your personal information with third parties only in the ways that are described in this Privacy Notice.

Healthcare providers involved in your medical care, such as your GP, specialists, and consultants
Health insurance providers, if applicable
Third-party service providers process data on our behalf, such as IT providers, billing providers, and courier services. We may also share your information with professional advisors acting as service providers, processors or controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services and to the extent that we are legally obliged to share or have a legitimate interest in sharing your personal data.
Regulatory and government bodies, as required by law
Emergency services, if necessary
Compliance with legal obligations. We may also disclose your personal information as required by law, such as: to comply with a subpoena or similar legal process; when we believe in good faith that disclosure is necessary to protect our rights; to protect your safety or the safety of others; to investigate fraud; or, to respond to a government request.
Affiliated businesses. Peamount Healthcare may share your personal information with affiliates to provide the services including access to the Site and to improve or develop the Site.

Donations

In order to make a donation to Peamount Healthcare you will be asked for information when you register with us. You will be required, amongst other things, to submit your name and email address. We will also require your credit card number. The information submitted will go directly to ‘idonate’ and they will be the controller of the data submitted

Data Retention

We will retain your personal data for as long as necessary to fulfil the purposes for which it was collected, as well as to comply with legal and regulatory requirements. The retention period may vary depending on the type of personal data and the purpose for which it was collected

How We Secure Your Personal Data

Peamount Healthcare takes reasonable and appropriate steps to protect the security of Personal Data against unauthorized or unlawful access, use, destruction, loss, alteration or disclosure. While we follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure.

International Transfer of Personal Data

Your Data may be transferred, stored and processed in one or more countries outside the European Economic Area (“EEA”), for example, when one of our service providers use employees or equipment based outside the EEA. For transfers of your Data to third parties outside of the EEA, we take additional steps in line with Data Protection Legislation. We will put in place adequate safeguards with respect to the protection of your privacy, fundamental rights and freedoms, and the exercise of your rights.

Adequacy Decisions: We rely on decisions from the European Commission where they recognise that certain countries and territories outside of the European Economic Area ensure an adequate level of protection for personal information. These decisions are referred to as “adequacy decisions”.
Standard Contractual Clauses: We utilise standard contractual clauses approved by the European Commission (and the equivalent standard contractual clauses for the UK, where appropriate) for transfers to the United States.

While transfers to countries that don’t have an adequacy decision typically take place on the basis of the standard contractual clauses, in certain circumstances, transfers can also take place on the basis of exemptions provided for under data protection law. For example, sharing with law enforcement, in emergency situations where we learn that a person’s life is at risk.

Where we transfer personal information from a non-EEA country to another country, you acknowledge that third parties in other jurisdictions may not be subject to similar data protection laws to the ones in our jurisdiction. There are risks if any such third party engages in any act or practice that would contravene the data privacy laws in our jurisdiction and this might mean that you will not be able to seek redress under our jurisdiction’s privacy laws.

Your Rights Relating to Your Personal Data

You have certain rights relating to your Personal Data, subject to local data protection laws. To exercise your rights in connection with Personal Data processed by Peamount Healthcare on its own behalf, please contact us by using the information in the “Contacting us” section, below.

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party).
Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit the data to another data controller.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Right to Lodge a Complaint

We are committed to working with you to obtain a fair resolution of any complaint or concern. You also have the right to complain to a supervisory authority: You have the right to lodge a complaint with a supervisory authority if you believe that your rights have been infringed. The supervisory authority in Ireland is the Data Protection Commissioner, which can be contacted at

21 Fitzwilliam Square South Dublin 2 D02 RD28 Ireland

Phone: +353 578 684 800 or 076 1104 800 Email: info@dataprotection.ie

Website: https://dataprotection.ie/

Contacting

To exercise your rights regarding your Personal Data, or if you have questions regarding this Privacy Notice or our privacy practices contact us at info@peamount.ie.

Changes To This Privacy Notice

We will update this Privacy Notice from time to time to reflect changes in our practices, technologies, legal requirements and other factors. If we do, we will reflect this in the “Last updated” date at the top of this Privacy Notice.