Global Diagnostics Privacy Statement
Global Diagnostics wants to ensure the highest standard of diagnostic care for our patients. We understand that a medical imaging facility is a trusted environment governed by an ethic of privacy and confidentiality. Our facilities conform with the Medical Council guidelines and the privacy principles of the Data Protection Legislation. This Privacy Statement is about making your consent meaningful by advising you of our policies and practices on dealing with your medical information.
Legal basis for processing your data
The processing of personal data in general practice is necessary in order to protect the Vital Interests of the patient and for the provision of health care and public health. Patient Consent will be requested for all third-party queries.
Managing your information
- To provide for your care we need to collect and keep information about you and your health on our records.
- Upon receipt of a diagnostic Referral Form signed by your referring clinician, we use this data to communicate with you in the interests of your own healthcare but will not forward it to anyone else without your expressed consent.
- We retain your information securely using digital technology however we do not process or transfer any data outside the European Economic Area (“EEA”).
- We will only ask for and keep information that is necessary. We will attempt to keep it as accurate and up to-date as possible. We will explain the need for any information we ask for if you are not sure why it is needed.
- Please inform us about any relevant changes that we should know about, such as change of address, phone numbers, and family circumstances, any new treatments or investigations being carried out that are relevant to your diagnostic investigation. For all contact information see: globaldiagnostics.ie/contact.html
- All non-service users and non-staff in our facilities (not already covered by a professional confidentiality code) who have access to any data, sign a confidentiality agreement that explicitly makes clear their duties in relation to personal health information and the consequences of breaching that duty.
- Access to patient records is regulated to ensure that they are used only to the extent necessary to enable the Clinicians and/or Admin team to perform their tasks for the proper functioning of the service. In this regard, patients should understand that our staff may have access to their records for:
- Opening Referral Forms from hospitals and consultants. These Referral Forms could be appended to a patient’s paper file or scanned into their electronic patient record.
- Identifying the examination(s) from the Referral Form and scheduling relevant examinations.
- Contacting you to arrange / change appointments
- Communicating with patients to complete patient safety questionnaires in advance of imaging procedures
- Scanning clinical letters, radiology reports and any other documents not available in electronic format.
- Dealing with patient complaints.
- Photocopying or printing documents for referral to GPs, consultants and hospitals.
- Handling, printing, photocopying, faxing and posting of radiology reports, and of associated documents.
- Exporting radiology images to portable electronic formats
- Sending diagnostic results to referring clinicians
- Sending diagnostic results to other clinicians if requested and consented by you
Consent for Minors
Where we are required to gather the personal information of a minor (defined as a person aged under 16 years), we will require the attendance and consent of a parent or guardian, and will only acquire and store such data with their permission, as well as the awareness of the minor themselves.
Where the parents of the minor are not in a position to provide such consent, the support of a recognised body will act ‘in loco parentis’ – for example the school principal, social worker or Gardai will be consulted with the medical professional in order to ensure that any such processing of personal data is being done in the vital interests of the minor. As much as possible, the minor will be made aware of the processing activity and its purposes.
Disclosure of information to other health and social professionals
We may need to pass some of this information to other health and social care professionals to provide you with the treatment and services you need. Only the relevant part of your record will be released. These other professionals are also legally bound to treat your information with the same duty of care and confidence that we do.
Disclosures Required or Permitted Under Law
The law provides that in certain instances personal information (including health information) can be disclosed in the following circumstances:
- Infectious diseases Under Health Act 1947 and 1953 plus amendments and Infectious Diseases Regs 1981 plus amendment Regs 2016, there is a list of diseases we are obliged to report e.g. Tuberculosis (TB), Measles, Anthrax, Lyme, Zika. For a full list please see https://www.hpsc.ie/notificablediseases/
- Disclosures to insurance companies or requests made by solicitors for your records we will only release the information with your signed explicit consent.
Data Retention Periods
For clarity our data retention policies adhere to the Data Protection Legislation including Article 5 guidelines on (GDPR) General Privacy Data Regulations effective from 25th May 2018.
For a comprehensive description of our retention Principles please reference: https://www.hiqa.ie/system/files/Guidance-on-information-governance.pdf
Use of Anonymised information for training, teaching and quality assurance
To provide the highest level of care to the patient, Clinical staff may access clinical information for training, audit, consultation or peer review. Accuracy of image interpretation by Radiologists is crucial to patient management. Peer review is a recognised mechanism for evaluating the diagnostic accuracy and completeness of Radiologists’ reports. As Medical Registration requires that a doctor’s performance is continuously assessed in as objective a way as possible, the practice of peer review is being promoted to maintain safe, high quality patient care. More information on audit and peer review in radiology can be found in the Guidelines for the Implementation of a National Radiology Quality Improvement Programme, of which Global Diagnostics adheres to http://www.radiology.ie/wp-content/uploads/2012/05/National-Radiology-QI-Guidelines-V31.pdf
Global Diagnostics is from time to time, involved in the clinical training of Undergraduate and Postgraduate health professionals who before commencement, sign a confidentiality agreement that explicitly makes clear their duties in relation to personal health information and the consequences of breaching that duty.
Global is also affiliated with a number of Universities for the purpose of anonymised research projects. If it were proposed to use your information in a way where it would not be anonymous or if we were involved in external research we would discuss this further with you before we proceeding and seek your written informed consent.
Right to Rectification
You have the right to have your information corrected, erased, restricted to specified individuals or object to it being processed. For clarity, this process is outlined on the Global Diagnostics Website in the section Privacy and Subject Access Request.
Your right of access to your health information
You have the right of access to all the personal information held about you by Global Diagnostics. If you wish to see your records in most cases it is the quickest to discuss this with your referring doctor who will outline the information in the diagnostic record with you. Alternatively, you can make a formal written access request to Global Diagnostics and the matter can be dealt with formally within 30 days.
Transferring to another medical imaging company
If you decide at any time and for whatever reason to attend another medical imaging company and require your diagnostics images and reports held by Global we will facilitate that decision by making available to your new medical imaging company a copy of your records on receipt of your signed consent. For medico-legal reasons we will also retain a copy of your records in this medical imaging company for an appropriate period of time which may exceed eight years.
For security reasons, some facilities may have CCTV cameras at the different access points in the building in order to prevent intruders or individuals who could damage property of that facility. As a member of the public or staff of Global Diagnostics or that facility your image will be captured on such CCTV cameras, however, we will only disclose such CCTV footage to other parties where necessary to investigate a break in or other unauthorised access to the facility.
Making a complaint
If Global Diagnostics do not agree to provide you with access to your personal information or you
have a complaint about our information handling practices you have a right to lodge a complaint with
our Data Protection Officer by email at DPO@centrichealth.ie or you can contact the Office of the Data Protection Commission by visiting https://www.dataprotection.ie/docs/complaints/1592.htm
We hope this statement has explained any issues that might arise. If you have any queries about this Privacy Statement, please email DPO@Centrichealth.ie.