Registered Social Worker ( Registration Number: 10-12811 ) Practice Number 0050202
Privacy Policy
Please read this Privacy Policy carefully to understand how your personal information will be handled by the Patrick Egan Professional Services. Every term of this Policy is material.
This Privacy Policy applies to Patrick Egan Professional Services and its subsidiaries and associates (if any).
Explanation of Terms
“Data subject” refers to the person or entity to whom the personal information relates.
“Patrick Egan Professional Services” refers to the entities listed above as the context requires.
“Personal information” has the meaning assigned to it in POPIA and refers to information relating to human beings and certain juristic persons. It includes information such as race, gender, pregnancy, age, health status and medical information, date of birth, identity number, contact details and confidential correspondence.
“Processing” has the meaning assigned to it in POPIA and refers to any operation or activity concerning personal information, such as the collection, receipt, recording, storage, updating, alteration, use, distribution, erasure or destruction of the information.
“POPIA” means the Protection of Personal Information Act (Act 4 of 2013) and its Regulations.
“We” / “us” refers to Patrick Egan Professional Services or any of the entities listed above as may be required in the context.
“You” / “your” refers to the data subject (i.e., the person or entity) whose personal information is processed by the practice.
Application of the Privacy Policy
This Privacy Policy applies to personal information that we have in our possession or under our control and personal information that we collect or receive from or about you. It stipulates, amongst others, how we collect the information, the type of information collected, why that information is collected, the circumstances under which that information will be shared with others, the security measures that we have implemented to protect the information and how you may obtain access to and correct your information.
Our Commitment
We understand that your personal information is important to you. Your privacy and the security of your information are just as important to us and we want to make sure you understand how your information will be processed. We are committed to conducting our business in accordance with the law. We will, therefore, only process, which includes collect, use, store or disclose, your personal information in accordance with the law or otherwise with your consent and will always strive to keep your information confidential. We take this commitment to look after your personal information seriously. We have implemented a number of processes to make sure that your personal information is used in the right way.
When You Provide Information about Another Individual / Entity
You must ensure that if you provide personal information about any individual or entity to us, you may lawfully do so (e.g. with their consent). We will accept that you are acting lawfully. You should make sure that they are familiar with this Privacy Policy and understand how we will use and disclose their information.
Collection of Your Personal Information
We collect personal information directly from you when you become a client of an Patrick Egan Professional Services and when you provide information to us.
Information may also be collected from other sources, depending on the circumstances, when it is, for example, not possible to obtain the information directly from you or to protect your legitimate interests such as ensuring your safety. The information may be collected from persons, such as your next-of-kin, another healthcare practitioner involved in your care or when you make information publicly available.
The information that we collect about patients is necessary to ensure their safety during treatment and to provide them with the requested psycho-social and or counselling services.
Processing of Your Personal Information
We generally process the personal information listed below, if applicable in the circumstances, and retain it as part of our records. Other personal information may be collected and processed if it is required in the circumstances.
Clients
There are various laws that permit the processing of personal information of patients such as the Health Care and the Mental Health Act, Social Service Professions Act etc.
Information collected may include:
Names and surnames, identity numbers, passport numbers, dates of birth, age, contact details, addresses, nationality and gender;
•Names and contact details of next-of-kin;
•Health status, medical information, including medical and psycho-social history;
•Medical scheme information or information about other relevant funders.
•Services performed / treatment provided and relevant reports (e.g., reports of client attendance and clinical notes and any requested reports);
•Billing and payment details;
•Information recorded on practice / facility documentation, such consent forms; and
•Client files for clinical process
Practitioners employed by the Practice
•Names and surnames, titles, identity numbers, dates of birth, age, contact details, addresses, statutory council number, nationality, gender, race, qualifications, specialisation, interests and other information included on CVs;
•Membership of professional bodies and registration
•Signatures of official signatories of the practice and proof of residence, if required by the bank;
•Bank details;
•Professional indemnity cover; and
•Correspondence.
Suppliers, Vendors and Other Persons or Entities
•Organisation’s name and contact details;
•Names, titles and contact details of relevant persons (including next-of-kin of patients and guarantors / authorised persons of patients);
•Agreements and related information;
•Financial information, including invoices;
•Official documentation, including newsletters and statements; and
•Correspondence.
Consent
If you consent to the processing of your personal information, you may withdraw your consent at any time. This does not affect the processing of personal information that has already occurred. If you withdraw your consent, your personal information will only be processed as provided for in the law.
Objection to Processing
When we process your personal information to protect your legitimate interests or based on the legitimate interests of Patrick Egan Professional Services or those of a third party to whom we supply the information, you may object to our processing, if it is reasonable to do so. This does not affect your personal information that we have already processed. If you object and we agree with your objection, your personal information will only be processed as provided for in the law.
Purposes of Processing of Your Personal Information
Patrick Egan Professional Services generally process your personal information for the following purposes:
To conduct and manage the practice in accordance with the law, including the administration of the practice and claiming and collecting payment for services rendered from relevant funders, patients and/or responsible persons / entities;
•For treatment and care of patients;
•For communication purposes (e.g. reminders of patient appointments);
•For the maintenance of practice / facility records and patients’ medical records;
•For employment / contracting and related matters of health care practitioners;
•For reporting to persons and bodies, including referring practitioners, as required and authorised in terms of the law or by the data subjects;
•For historical, statistical and research purposes;
•For clinical trials / research studies;
•For identification of patients;
•For enforcement of the practice’s rights; and/or
•For any other lawful purpose related to the activities of our practice.
Disclosure of Your Personal Information
We will share only relevant personal information about you with the persons and entities if it is necessary and lawful in the circumstances. Information may be disclosed to
Client
•Relevant funders such as the patient’s medical scheme;
•Practitioners and employees of the practice and service providers who assist us to provide the services and who perform functions related to the administration of the practice on a need-to-know basis, subject to confidentiality undertakings;
•Debt collectors / attorneys;
•Our insurers;
•Our professional and legal advisers, including our accountants / auditors;
•Law enforcement structures, including courts and tribunals;
•Regulatory and other public or private bodies, persons or entities, as may be required or permitted in terms of the law, including to comply with any legal obligation or to protect the rights, property or safety of our practice, employees, patients, the public or others;
•Next-of-kin in emergency situations; and
•Any successor in title of the relevant entity.
Record-Keeping
We maintain records of your personal information for as long as it is necessary for lawful purposes related to the conducting of our business, including to provide treatment and care to patients, comply with legal obligations, resolve complaints, attend to litigation (if applicable), enforce agreements and for historical, statistical and research purposes subject to the provisions of the law.
Information Sent Across the Borders of the Republic of South Africa
We process and store your information in records within the Republic South Africa. If we must provide your personal information to any third party in another country, we will obtain your prior consent unless such information may be lawfully provided to that third party.
Security of Your Personal Information
We are committed to ensuring the security of your personal information in order to protect it from unauthorised processing and access as well as loss, damage or unauthorised destruction. We have implemented and continually review and update our information protection measures to ensure the security, integrity, and confidentiality of your information in accordance with industry best practices. These measures include the physical securing of the offices where information is held, the locking of cabinets with physical records, password control to access electronic records, off-site data back-ups and stringent policies in respect of electronic record storage and dissemination. In addition, only those employees and service providers that require access to your information to discharge their functions and to render services to us are granted access to your information and only if they have concluded agreements with or provided undertakings regarding the implementation of appropriate security measures, maintaining confidentiality and processing the information only for the agreed purposes. We will inform you and the Information Regulator, if any person has unlawfully obtained access to your personal information, subject to the provisions of the law.
Right to Access your Personal Information
You have the right to request access to your personal information in our possession or under our control and information of third parties to whom we supplied that information subject to restrictions imposed in legislation.
Accuracy of Your Personal Information
It is important that we always have accurate information about you on record as it could impact on communication with you and your health, if applicable. You must therefore inform us as soon as any of your information has changed. You may also request us to correct or delete any information. You must provide sufficient detail to identify the information and the correction / deletion required. Information will only be corrected / deleted, if we agree that the information is incorrect or should be deleted. It may not be possible to delete all the information if we may lawfully retain it.
Changes to this Privacy Policy
We reserve the right in our sole and absolute discretion, to revise or supplement this Privacy Policy from time to time to reflect, amongst others, any changes in our practice or the law. We will publish the updated Privacy Policy on our website. Any revised version of the Policy will be effective as of the date of posting on the website, so you should always refer back to the website for the latest version of the Policy. It is your responsibility to make sure you are satisfied with any changes before continuing to use our services.
Concerns and Complaints about the Processing of Your Personal Information
All enquiries, requests or concerns regarding this Policy or relating to the processing of your personal information by the practice should be addressed to the practice.
Laws Applicable to this Privacy Policy
This Privacy Policy is governed by the laws of the Republic of South Africa