Privacy Policy

Contents

1.0 Purpose

2.0 The information we process

3.0 Legal basis for processing

4.0 How we obtain information

5.0 Your rights

6.0 Access your health records

7.0 Who is the data controller?

8.0 Your Information may be used to

9.0 What other use is made of your Information

10.0 Sharing with third parties

11.0 Transferring information overseas

12.0 How do we keep your records secure and confidential?

13.0 Sharing Information – within Lucand Medical Services

14.0 Retention period

15.0 Contact details

1.0 Purpose

• 1.1 Lucand Medical Services must comply with all applicable data protection, privacy, and security laws and regulations in the locations in which we operate.
• 1.2 We respect your rights to privacy and the protection of your personal information.
• 1.3 The purpose of this privacy notice is to explain how we collect and use personal information for the provision of our occupational health services and the day-to-day running of Lucand Medical Services.

2.0 The information we process

2.1 To allow us to provide our services to you, we collect and process various categories of personal information.

2.2 Information we collect may include:

• 2.2.1 Personal details about you, such as date of birth, address, next of kin, contact details (mobile phone number) etc.
• 2.2.2 Notes and reports about your health needs
• 2.2.3 Results of investigations, such as X-rays and laboratory tests
• 2.2.4 Relevant information from other health and social care professionals, your carers, or relatives
• 2.2.5 We may also process certain special categories of information, which may include racial or ethnic origin, data concerning health, or data concerning a person’s sex life.

3.0 Legal basis for processing

3.1 Lucand Medical Services’s lawful basis for processing personal data of service users is as follows:

• 3.1.1 The processing is necessary in order to protect the vital interests of the person (referred to as the data subject in Data Protection language). This would apply in emergency situations.
• 3.1.2 The processing is necessary for a task carried out in the public interest or in the exercise of official authority vested in the controller; for Lucand Medical Services this official authority is vested in us through the Health Act 2004 (as amended).
• 3.1.3 Special categories of data are defined by the GDPR and include items like racial or ethnic origin, health data and sexual orientation.

3.2 We will only process special categories of personal data where it is necessary:

• 3.2.1 For the purposes of preventative or occupational medicine
• 3.2.2 For the assessment of the working capacity of an employee
• 3.2.3 For medical diagnosis
• 3.2.4 For the provision of healthcare, treatment or social care
• 3.2.5 Pursuant to a contract with a health professional.

3.3 Processing is lawful where it is undertaken by or under the responsibility of:

• 3.3.1 A health practitioner
• 3.3.2 A person who in the circumstances owes a duty of confidentiality to the data subject that is equivalent to that which would exist if that person were a health practitioner. For example, Lucand Medical Services administrative staff etc.

3.4 If the purpose of the processing is for a reason other than the reasons above, we will seek explicit consent to process your sensitive personal data (referred to as ‘special categories’ of data under the GDPR).

4.0 How we obtain information

4.1 We may obtain your information from a variety of sources, including information you give to us. We may also receive your personal information from third parties, for example your employer by means of a management referral and treating physicians.

5.0 Your rights

5.1 You have certain legal rights concerning your information and the manner in which we process it. This includes:

• 5.1.1 A right to get access to your personal information
• 5.1.2 A right to request us to correct inaccurate information, or update incomplete information
• 5.1.3 A right to request that we restrict the processing of your information in certain circumstances
• 5.1.4 A right to request the deletion of personal information excluding medical records
• 5.1.5 A right to receive the personal information you provided to us in a portable format
• 5.1.6 A right to object to us processing your personal information in certain circumstances
• 5.1.7 A right to lodge a complaint with the data protection commission.

6.0 Access your health records

6.1. You can access your health records by making a subject access request (SAR) and forms are available for this purpose by emailing conor@lucandmedicalservices.ie.

6.2 It is important that you provide satisfactory evidence of identification and a sufficient description of the data that you are looking for.

7.0 Who is the data controller?

7.1 The data controller in most instances is determined at the outset of engagement with a client organisation and is explicitly stated in a service level agreement.

7.2 In general terms, the client organisation is the data controller.

8.0 Your Information may be used to

8.1 Review the care we provide for you to ensure it is of the highest standard

8.2 Investigate complaints, legal claims or adverse incidents

8.3 Protect wider public health interests

8.4 Provide information for planning so we can meet future needs for health and social care services

8.5 Provide information to prepare statistics on Service performance

8.6 Carry out health audit

8.7 Provide training and development

8.8 Remind you of appointments by text

9.0 What other use is made of your Information

9.1 Lucand Medical Services provides statistical information to client organisations.

9.2 Lucand Medical Services will make sure that you cannot be identified by anonymising the information.

9.3 If it is not possible to anonymise the information, you will be contacted for your consent.

10.0 Sharing with third parties

10.1 You may also be receiving healthcare from providers outside of Lucand Medical Services.

10.2 In order to assist in this process, we may make referrals on your behalf requiring the need to share your personal information with those providers.

10.3 We will only do so if there is a genuine need in order to ensure the highest quality of care is provided to you and with your prior written consent.

10.4 We are careful only to share the information that is necessary for this purpose. Anyone who receives this information is also bound by confidentiality and the data protection laws.

10.5 In certain situations, we may have to disclose your personal information to other agencies, in accordance with legal requirements e.g. the Courts, or in an emergency situation to prevent injury to other persons.

11.0 Transferring information overseas

11.1 With your prior consent, we may transfer your information to organisations in other countries which is necessary to provide you with health and social care services, on the basis that anyone to whom we pass it protects it in the same way we would and in accordance with applicable laws.

12.0 How do we keep your records secure and confidential?

12.1 We are committed to ensuring that your information is secure with us and with the third parties who act on our behalf.

12.2 We have a number of security precautions in place to prevent the loss, misuse or alteration of your information.

12.3 All staff working for Lucand Medical Services have a legal duty to keep information about you confidential and all staff are trained in information security and confidentiality.

12.4 Lucand Medical Services has strict information security policies and procedures in place to ensure that information about you is safe, whether it is held in paper or electronic format.

13.0 Sharing Information – within Lucand Medical Services

13.1 Within Lucand Medical Services, the clinical information collected by a clinician or staff member authorized to process your data is passed on to other clinicians within

Lucand Medical Services, when it is considered necessary for your occupational health care needs.

14.0 Retention period

14.1 We will only retain information for as long as necessary. Records are held in accordance with Lucand Medical Services’s Records Retention Policy.

15.0 Contact details

15.1 Please contact our Data Protection Officer:

• 15.1.1 If you have any queries in relation to Data Protection or other issues around the security of your personal information.
• 15.1.2 For more information about the steps we are taking to protect your information
• 15.1.3 For more information about your rights, including the circumstances in which you can exercise them and how to exercise them
• 15.1.4 If you wish to raise a complaint on how we have handled your personal information, you can contact our Data Protection Officer who will investigate the matter. We hope that we can address any concerns you may have.

Data Protection Officer: Dr Conor McDonnell

Email: conor@lucandmedicalservices.ie

Phone: 0818 543311

Address: Lucand Medical Services Services ULC, Annadrumman, Templehill, Carrigrohane, Cork. T12N2DN