PRIVACY POLICY

NOTICE OF PRIVACY POLICY AND PRACTICES

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION.  PLEASE REVIEW IT CAREFULLY.

The International Health Centre The Hague (IHCH) respects your privacy. We understand that your personal health information is very sensitive. We will not disclose your information to others unless you tell us to do so, or unless the law authorises or requires us to do so.

The law protects the privacy of the health information we create and obtain in providing our care and services to you. For example, your protected health information includes your symptoms, test results, diagnoses, and treatment, health information from other providers, as well as billing and payment information relating to these services. State law allows us to use and disclose your protected health information for purposes of treatment and health care operations. State law requires us to get your authorisation to disclose this information for payment purposes.

How do we collect your personal data?

• Directly from you
• Through third parties
• We also collect certain data automatically when you access our website, or when you read or click on the e-mails which we send you, or when you yourself provide us with them

What data is being collected?

Depending on the circumstances, we can compile in whole or in part the information listed next in order to offer you the medical services that better fit your situation and interests:

From you:

• name;
• contact information (mail, postal address, telephone);
• additional information you share with us;

The list above is neither limited nor comprehensive regarding the categories of personal data that we might collect.

From Your Activity:  Information that we automatically collect when you use our Website, including, without limitation:

• IP addresses, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device; browser type and language; referring and exit pages and URLs; date and time; amount of time spent on particular pages; what sections of the Websites you visit; and similar data; and
• Information about your device, including the type of device; universally unique ID (“UUID”); advertising identifier (“IDFA”); MAC address; operating system and version (e.g., iOS, Android or Windows); carrier and country location; hardware and processor information (e.g., storage, chip speed, camera resolution, NFC enabled); network type (WiFi, 3G, 4G, LTE); and similar data.

From Third-Party Analytics:  We use third-party analytics services (such as Google Analytics) to evaluate your use of the Websites, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Websites and mobile and Internet usage.  These third parties use cookies and other technologies to help analyze and provide us the data. By accessing and using the Website, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.

Why we use cookies

In order to improve our services, to provide you with more relevant content and to analyse how visitors use our website, we may use technologies, such as cookies, pixels or tracking software. Please be aware that in most cases we will not be able to identify you from the information we collect using these technologies.

For example, we use software to monitor customer traffic patterns and website usage to help us develop the design and layout of the website in order to enhance the experience of the visitors to our website. This software doesn’t let us collect any personal data. In addition, in order to understand how our customers interact with the emails and the content that we send, we use pixels that allow us to know if the emails we send are opened or if the content of our emails is displayed in text or html form.

What is the purpose of collecting your personal data?

We will collect and process the information you provided with the following purposes:

• To answer to your request for information or for professional advice
• For purposes of medical treatment and health care operations
• To establish contact with you in order to provide you information about medical advice and/or our services
• To inform you electronically about our professional services
• To send commercial and / or promotional information, as well as informative circulars

What are we doing with your personal data?

Examples of use and disclosures of protected health information for treatment, payment, and health operations are as follows:

• For treatment:
  • Information obtained by a nurse, physician, psychologist or other member of our health care team will be recorded in your medical record and used to help decide what care may be right for you.
  • We may also provide information to others providing you care. This will help them stay informed about your care.
• For payment:
• We request payment from your health insurance plan/company. Health plans/companies may need information from us about your medical care. Information provided to health plans may include your diagnoses; procedures performed, or recommended care.
• For health care operations:
  • We use your medical records to assess quality and improve services.
  • We may use and disclose medical records to review the qualifications and performance of our health care providers and to train our staff.
  • We may contact you to remind you about appointments and give you information about treatment alternatives or other health-related benefits and services.
• For marketing of IHCH and her daughter companies:
• We will use your e-mail address to inform you about new medical services, changes, and relevant medical information

We may use and disclose your information to conduct or arrange for services, including:

• Medical quality review by your health plan;
• Accounting, legal, risk management, and insurance services;
• Audit functions, including fraud and abuse detection and compliance programs.
• The health and billing records we create and store are the property of the practice/health care facility. The protected health information in it, however, generally belongs to you.

With whom do we share your personal data?

We will ensure that your Personal Data is processed in a manner that is compatible with the purposes indicated above and data may be communicated, where strictly necessary, to the following recipients or categories of recipients

• We will never sell your data to third parties, except access by the Company’s employees, and those cessions that might be carried out following a legal obligation.
• With your consent we may provide information to other healthcare providers that are or will be providing you care.
• Health plans/companies may need information from us about your medical care. Information provided to health plans may include your diagnoses; procedures performed, or recommended care.
• With your consent, we may release health information about you to a friend or family member who is involved in your medical care.  We may also give information to someone who helps pay for your care.  We may tell your family or friends your condition and that you are in
• We may disclose health information about you to assist in disaster relief efforts.

You have the right to object to this use or disclosure of your information. If you object, we will not use or disclose it.

We may use and disclose your protected health information without your authorisation as follows:

• With medical researchers, if the research has been approved and has policies to protect the privacy of your health information. We may also share information with medical researchers preparing to conduct a research project.
• To funeral directors/coroners consistent with applicable law to allow them to carry out their duties.
• To organ procurement organisations (tissue donation and transplant) or persons who obtain, store, or transplant organs.
• To the Dutch Ministry of Health relating to problems with food, supplements, and products.
• To comply with workers’ compensation laws, if you make a workers’ compensation claim.
• For public health and safety purposes as allowed or required by law:
• To prevent or reduce a serious, immediate threat to the health or safety of a person or the public;
• To public health or legal authorities;
• To protect public health and safety;
• To prevent or control disease, injury, or disability;
• To report vital statistics such as births or deaths
• To report suspected abuse or neglect to public authorities.
• To correctional institutions if you are in jail or prison, as necessary for your health and the health and safety of others.
• For law enforcement purposes such as when we receive a subpoena, court order, or other legal process, or you are the victim of a crime.
• For health and safety oversight activities. For example, we may share health information with the Department of Health.
• For disaster relief purposes. For example, we may share health information with disaster relief agencies to assist in notification of your condition to family or others.
• For work-related conditions that could affect employee health. For example, an employer may ask us to assess health risks on a job site.
• In the course of judicial/administrative proceedings at your request, or as directed by a subpoena or court order.
• For specialised government functions. For example, we may share information for national security purposes.

Other uses and disclosures of protected health information:

• Uses and disclosures not in this Notice will be made only as allowed or required by law or with your written authorization.

What are your rights regarding your personal data that we have collected?

You have a right to:

• Request and receive a paper copy of the most current Notice of Privacy Practices for Protected Health Information (“Notice”)
• Receive, read, and ask questions about our Notice of Privacy Policy
• Ask us to restrict certain uses and disclosures. You must deliver this request in writing to us. We are not required to grant the request, but we will comply with any request granted
• Request that you be allowed to see and get a copy of your protected health information. You may make this request in writing. We have a form available for this type of request.
• Have us review a denial of access to your health information, except in certain circumstances
• Ask us to change your health information. You may give us this request in writing. You may write a statement of disagreement if your request is denied. It will be stored in your medical record and included with any release of your records.
• When you request, we will give you a list of disclosures of your health information. The list will not include disclosures to third party payers. You may receive this information without charge once every 12 months. We will notify you of the cost involved if you request this information more than once in 12 months.
• Ask that your health information be given to you by another means or at another location. Please sign, date, and give us your request in writing.
• Cancel prior authorisations to use or disclose health information by giving us a written revocation. Your revocation does not affect information that has already been released. It also does not affect any action taken before we have it. Sometimes, you cannot cancel an authorization if its purpose was to obtain insurance.
• Ask us to remove your email address from our mailing lists.

Our responsibilities

We are required to:

• Keep your protected health information private;
• Give you this Notice;
• Follow the terms of this Notice.

We have the right to change our practices regarding the protected health information we maintain. If we make changes, we will update this Notice. You may receive the most recent copy of this Notice by calling and asking for it, by visiting our website or by visiting our Administration Department to pick one up.

How do we keep your personal data protected?

In order to grant the protection of your data and keep its confidentiality, integrity and availability, we implement several security measures.

Although it is not possible to grant absolute protection against intrusions on data transfer through the internet or from a web, we devote our best efforts to keep the physical, electronic and procedural protection measures of your data with which we grant the safeguard of your data according to the legal requirements applicable in this matter. Amongst the measures we use we include the following:

• To limit the access to your data exclusively to those persons who must be aware of them as per the tasks they perform;
• As a general rule, to transfer the obtained data in encrypted format;
• To store the most sensitive data exclusively in encrypted format;
• To install protection systems in computer infrastructures (firewalls) to avoid unauthorized accesses, for example, hackers;
• To regularly monitor the access to computer systems in order to detect and intercept any inappropriate usage of personal data;
• In the instance in which we may have provided (or you may have chosen) a password allowing access to certain areas of our webs or any other portal, application or service under our control, you are held responsible to keep it secret and to follow all the security procedures that we share with you. You will not be allowed to share your password with no one.

How long do we keep your Personal Data?

We undertake to retain your Personal Data only for as long as necessary to fulfil the commitments for which the data was collected or to fulfil legal obligations

Rules on taking photos, filming and sound recordings

• In order to protect the privacy of our patients and staff, there are rules in place on taking photos, filming and sound recordings. The rules below apply to patients and visitors.
• You are allowed to take photos of and film yourself in the clinic, but no other patients or staff may be recognizable visually or audibly.
• Please exercise restraint when taking photos of or filming others. If you wish to film somebody, please seek permission from that person first. Ensure that you also mention what you are intending to do with the photo or film.
• If somebody is unable to give consent, then you may not take any photos of that person or film them. Neither are you allowed to take photos of or film children other then yours.
• If you wish to share a photo or film on social media, for instance, please always ensure that no other people are visible in the background of your photo/film.
• The use of hidden cameras is not permitted in the IHCH.
• You are allowed to record a consultation with your physician, please inform him or her that you are doing so.

Rules on the use of social media

Naturally, you are entitled to let people know what you think of the IHCH via social media. In fact, we encourage you to do so! However, there are a few rules with regard to posting photos or films that you have taken/recorded in the IHCH and the use of social media:

With due regard for the above rules for taking photos, filming and sound recordings, always seek the prior consent of the people you wish to photograph or film. Ensure that you also mention what you intend to do with the photo or film.

To ask for help or complain

If you have questions, want more information, or want to report a problem about the handling of your protected health information, you may contact us by email or by post as follows:

ihchict@ezorg.nl, Privacy Officer
International Health Centre The Hague
Jan van Nassaustraat 125, 2596BS The Hague
Phone +31 (0)70 306 5100, Fax +31 (0)70 306 5123
E-mail: ihchinfo@ezorg.nl

If you believe your privacy rights have been violated, you may discuss your concerns with any staff member. You may also deliver a written complaint to the above address.

This privacy notice was last updated on April 14th, 2021.

Web Site

www.ihch.nl

Effective Date: April 14th, 2021