Interpretation.

Definitions:

Automated Decision-Making (ADM): when a decision is made which is based solely on Automated Processing (including profiling) which produces legal effects or significantly affects an individual. The GDPR prohibits Automated Decision-Making (unless certain conditions are met) but not Automated Processing.

Automated Processing: any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that individual's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. Profiling is an example of Automated Processing.

Company name: INTEGRATED MEDICAL SOLUTIONS INTERNATIONAL Ltd.

Company Personnel: all patients, employees, workers, contractors, agency workers, consultants, directors, members and others.

Consent: agreement which must be freely given, specific, informed and be an unambiguous indication of the Data Subject's wishes by which they, by a statement or by a clear positive action, signify agreement to the Processing of Personal Data relating to them.

Controller: the person or organisation that determines when, why and how to process Personal Data. It is responsible for establishing practices and policies in line with the GDPR. We are the Controller of all Personal Data relating to our Company Personnel and Personal Data used in our business for our own commercial purposes.

Data Subject: a living, identified or identifiable individual about whom we hold Personal Data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data

Explicit Consent: consent which requires a very clear and specific statement (that is, not just action).

General Data Protection Regulation (GDPR): the General Data Protection Regulation ((EU) 2016/679). Personal Data is subject to the legal safeguards specified in the GDPR.

Personal Data: any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data includes Special Categories of Personal Data and Pseudonymised Personal Data but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person's actions or behaviour.

Personal Data Breach: any act or omission that compromises the security, confidentiality, integrity or availability of Personal Data or the physical, technical, administrative or organisational safeguards that we or our third-party service providers put in place to protect it. The loss, or unauthorised access, disclosure or acquisition, of Personal Data is a Personal Data Breach.

Privacy by Design: implementing appropriate technical and organisational measures in an effective manner to ensure compliance with the GDPR.

Processing or Process: any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.

Pseudonymisation or Pseudonymised: replacing information that directly or indirectly identifies an individual with one or more artificial identifiers or pseudonyms so that the person, to whom the data relates, cannot be identified without the use of additional information which is meant to be kept separately and secure.

Introduction

This Privacy Standard sets out how DR DAVID O’CONNELL ("we", "our", "us") handle the Personal Data of our patients, customers, suppliers, employees, workers and other third parties.

This Privacy Standard applies to all Personal Data we Process regardless of the media on which that data is stored or whether it relates to past or present patients, employees, workers, customers, clients or supplier contacts, shareholders, website users or any other Data Subject.

Scope

We recognise that the correct and lawful treatment of Personal Data will maintain confidence in the organisation and will provide for successful business operations. Protecting the confidentiality and integrity of Personal Data is a critical responsibility that we take seriously at all times.

All [CEOs,] [individual business areas,] [units,] [departments,] [supervisors,] [[OTHER RESPONSIBLE PARTIES]] are responsible for ensuring all Company Personnel comply with this Privacy Standard and need to implement appropriate practices, processes, controls and training to ensure that compliance.

The DPO is responsible for overseeing this Privacy Standard and, as applicable, developing Related Policies and Privacy Guidelines. [That post is held by [NAME], [DEPARTMENT], [TELEPHONE EXTENSION], [EMAIL ADDRESS].]

Please contact the DPO with any questions about the operation of this Privacy Standard or the GDPR or if you have any concerns that this Privacy Standard is not being or has not been followed. In particular, you must always contact the DPO in the following circumstances:

if you are unsure of the lawful basis which you are relying on to process Personal Data (including the legitimate interests used by the Company) (see paragraph 5.1);

if you need to rely on Consent and/or need to capture Explicit Consent (see paragraph 6);

if you need to draft Privacy Notices (see paragraph 7);

if you are unsure about the retention period for the Personal Data being Processed (see paragraph 11);

if you are unsure about what security or other measures you need to implement to protect Personal Data (see paragraph 12.1);

Personal data protection principles

We adhere to the principles relating to Processing of Personal Data set out in the GDPR which require Personal Data to be:

Processed lawfully, fairly and in a transparent manner.

Collected only for specified, explicit and legitimate purposes.

Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.

Accurate and where necessary kept up to date.

Not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is processed.

Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage.

Not transferred to another country without appropriate safeguards being in place.

Made available to Data Subjects and allow Data Subjects to exercise certain rights in relation to their Personal Data.

We are responsible for and must be able to demonstrate compliance with the data protection principles listed above.

Lawfulness, fairness, transparency

Lawfulness and fairness

Personal data must be processed lawfully, fairly and in a transparent manner in relation to the Data Subject.

We may only collect, Process and share Personal Data fairly and lawfully and for specified purposes. The GDPR restricts our actions regarding Personal Data to specified lawful purposes. These restrictions are not intended to prevent Processing, but ensure that we Process Personal Data fairly and without adversely affecting the Data Subject.

The GDPR allows Processing for specific purposes, some of which are set out below:

the Data Subject has given his or her Consent;

the Processing is necessary for the performance of a contract with the Data Subject;

to meet our legal compliance obligations;

to protect the Data Subject's vital interests;

To pursue our legitimate interests for purposes where they are not overridden because the Processing prejudices the interests or fundamental rights and freedoms of Data Subjects. The purposes for which we process Personal Data for legitimate interests need to be set out in applicable Privacy Notices.

Whenever we collect Personal Data directly from Data Subjects, including for human resources or employment purposes, we must provide the Data Subject with all the information required by the GDPR including the identity of the Controller and DPO, how and why we will use, Process, disclose, protect and retain that Personal Data through a Privacy Notice which must be presented when the Data Subject first provides the Personal Data.

Purpose limitation

Personal Data will be collected only for specified, explicit and legitimate purposes. It will not be further Processed in any manner incompatible with those purposes.

Data minimisation

Personal Data will be adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed

Accuracy

Personal Data will be accurate and, where necessary, kept up to date. It must be corrected or deleted without delay when inaccurate.

You will ensure that the Personal Data we use and hold is accurate, complete, kept up to date and relevant to the purpose for which we collected it. You must check the accuracy of any Personal Data at the point of collection and at regular intervals afterwards. You must take all reasonable steps to destroy or amend inaccurate or out-of-date Personal Data.

Storage limitation

Personal Data must not be kept in an identifiable form for longer than is necessary for the purposes for which the data is processed.

Security integrity and confidentiality

Protecting Personal Data

Personal Data will be secured by appropriate technical and organisational measures against unauthorised or unlawful Processing, and against accidental loss, destruction or damage.

Reporting a Personal Data Breach

The GDPR requires Controllers to notify any Personal Data Breach to the applicable regulator and, in certain instances, the Data Subject.

We have put in place procedures to deal with any suspected Personal Data Breach and will notify Data Subjects or any applicable regulator where we are legally required to do so.

Data Subject's rights and requests

Data Subjects have rights when it comes to how we handle their Personal Data. These include rights to:

  • withdraw Consent to Processing at any time;
  • request access to their Personal Data that we hold;
  • prevent our use of their Personal Data for direct marketing purposes;
  • ask us to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or Processed or to rectify inaccurate data or to complete incomplete data;
  • restrict Processing in specific circumstances;
  • challenge Processing which has been justified on the basis of our legitimate interests or in the public interest;
  • prevent Processing that is likely to cause damage or distress to the Data Subject or anyone else;
  • be notified of a Personal Data Breach which is likely to result in high risk to their rights and freedoms;
  • make a complaint to the supervisory authority;
  • in limited circumstances, receive or ask for their Personal Data to be transferred to a third party in a structured, commonly used and machine-readable format.

Direct marketing

We are subject to certain rules and privacy laws when marketing to our customers.

For example, a Data Subject's prior consent is required for electronic direct marketing (for example, by email, text or automated calls). The limited exception for existing customers known as "soft opt-in" allows organisations to send marketing texts or emails if they have obtained contact details in the course of a sale to that person, they are marketing similar products or services, and they gave the person an opportunity to opt out of marketing when first collecting the details and in every subsequent message.

The right to object to direct marketing must be explicitly offered to the Data Subject in an intelligible manner so that it is clearly distinguishable from other information.

A Data Subject's objection to direct marketing must be promptly honoured. If a customer opts out at any time, their details should be suppressed as soon as possible. Suppression involves retaining just enough information to ensure that marketing preferences are respected in the future.

Sharing Personal Data

Generally we are not allowed to share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in place.

You may only share the Personal Data we hold with third parties, such as our service providers, if:

they have a need to know the information for the purposes of providing the contracted services;

sharing the Personal Data complies with the Privacy Notice provided to the Data Subject and, if required, the Data Subject's Consent has been obtained;

the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place.

Changes to this Privacy Standard

We keep this Privacy Standard under regular review.

This Privacy Standard does not override any applicable national data privacy laws and regulations in countries where the practice operates.

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