Política de Privacidade
The privacy and security of your personal information is our foremost concern, it is the cornerstone of our operations. As Best Doctors is a leading provider of health services throughout the world, we would not be able to operate in this global marketplace without proper policies and procedures to meet stringent international regulations.
Our policies and procedures are based upon the United States Health Insurance Portability and Accountability Act of 1996, as amended to date (HIPAA), and are revised market-by-market pursuant to the local market requirements. Your personal information will never be used for any purpose other than to provide you the service you have requested of Best Doctors. Your information will never be sold to any third party, for any purpose. We will never share or use your personal information for any purpose without an express written consent from you.
Best Doctors, Inc., and our subsidiaries through the world (“Best Doctors”), treats the privacy and security of your Personal Information as our foremost concern, it is the cornerstone of our operations. As Best Doctors is a leading provider of health services throughout the world, we would not be able to operate in this global marketplace without proper policies and procedures to meet stringent international regulations.
Our policies and procedures are based upon the United States Health Insurance Portability and Accountability Act of 1996, as amended to date, together with the rules and regulations promulgated thereunder (collectively, the “HIPAA Privacy Rules”), and are revised market-by-market by our subsidiaries pursuant to local market requirements. Your Personal Information will never be used for any purpose other than to provide you the service you have requested of Best Doctors. Your information will never be sold to any third party, for any purpose. We will never share or use your Personal Information for any purpose without an express written consent from you.
Best Doctors carefully protects the confidentiality of Personal Information provided to it by consumers, employees, healthcare professionals and business partners. Best Doctors values the confidence of its consumers, employees, healthcare professionals and business partners. Best Doctors will not release Personal Information to third parties about consumers, employees, healthcare professionals or business partners for purposes other than providing services which have been agreed or to comply with applicable legal requirements. Best Doctors is committed to maintaining leading industry practices in our use, collection and protection of Personal Information.
2. Safe Harbor
The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the “Safe Harbor Principles”) to enable U.S. companies to satisfy the requirement under European Union law that adequate protection is given to Personal Information transferred from the EU to the United States. The EEA has also recognized the U.S. Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001, p.47). Best Doctors is committed to protecting personal privacy and adheres to the seven Safe Harbor principles.
For purposes of this Policy, the following definitions shall apply:
• “Agent” means any third party that collects or uses Personal Information under the instructions of Best Doctors or to which Best Doctors discloses Personal Information for use on Best Doctors’ behalf. These third parties are most commonly individual doctors and hospitals in the United States of America, all of whom must comply with the HIPAA Privacy Rule.
• “Personal Information” means any information or set of information that identifies or is used by or on behalf of Best Doctors to identify an individual in the context of providing the Best Doctors’ services. Personal Information does not include information that is encoded or anonymised (or de-identified), or information that is publicly available and has not been combined with Personal Information that is not publicly available.
• “Sensitive Personal Information” means Personal Information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. Best Doctors will treat any information received from a third party as Sensitive Personal Information where that third party treats and identifies the information as Sensitive Personal Information.
5. Privacy Principles
The privacy principles in this Policy are based on the Safe Harbor Principles.
• Notice: Where Best Doctors collects Personal Information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses Personal Information about them, namely the provision of the Best Doctors’ services requested. Best Doctors will only provide Personal Information to Agents for the purposes of providing the Best Doctors’ services to the relevant individual. These Agents are most commonly doctors, hospitals or other healthcare professionals within the United States of America who are subject to the HIPAA Privacy Rule.
Notice will be provided in the form of, amongst other documentation, a InterConsultation Information Pack when individuals are first asked to provide personal information to Best Doctors, or as soon as practicable thereafter, and in any event before Best Doctors uses or discloses the information.
Where Best Doctors receives Personal Information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals in respect of their Personal Information.
• Choice: Best Doctors does not use Personal Information for purposes other than for which it was collected, i.e., the provision of the Best Doctors’ services relevant to the individual. Such information is not disclosed to any other third parties, other than Agents.
• Data Integrity: Best Doctors will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Best Doctors will take all reasonable steps to ensure that Personal Information is relevant to its intended use and is accurate, complete, and up-to-date and does so in order to provide the very best services.
• Transfers To Agents: Best Doctors most commonly transfers Personal Information to Agents who are subject to the HIPAA Privacy Rule. As such they must safeguard Personal Information in a way that is consistent with the HIPAA Privacy Rule and the terms of this Policy. In the event that information is transferred to Agents who are not subject to the HIPAA Privacy Rule appropriate assurances will be sought from these Agents. These may include: a contract obligating the Agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), Safe Harbor certification by the Agent, or being subject to another European Commission adequacy finding (e.g., companies located in Switzerland). Where Best Doctors has knowledge that an Agent is using or disclosing Personal Information in a manner contrary to this Policy, Best Doctors will take all reasonable steps to prevent that use or disclosure.
• Access And Correction: Upon request, Best Doctors will grant individuals reasonable access to the Personal Information of such individual that Best Doctors holds. This consists mainly of information received from third parties. In addition, Best Doctors will take reasonable steps to permit individuals to correct, amend, or delete information that is inaccurate or incomplete with the relevant third party. Best Doctors is unable to correct anything other than factual errors in any report Best Doctors may produce for its consumers because it is based on information provided by third parties. However, Best Doctors will take all reasonable steps to facilitate amendments to information provided by third parties if an individual raises a query and document such information in Best Doctors own records.
• Security: Best Doctors will take all reasonable precautions to protect Personal Information in its possession from loss, misuse and unauthorized access. In addition, Best Doctors will take all reasonable steps to prevent unauthorized disclosure, alteration and destruction of Personal Information.
• Enforcement: Best Doctors will conduct compliance audits of its relevant privacy practices, for example its information systems and data processing installations, to verify adherence to this Policy. Any employee that Best Doctors determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.
• Dispute Resolution: Any questions or concerns regarding the use or disclosure of Personal Information should be directed to the Best Doctors Privacy Officer at the address given below. Best Doctors will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between Best Doctors and the complainant, Best Doctors has agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities to resolve disputes pursuant to the Safe Harbor Principles.
6. Limitation On Application Of Principles
Adherence by Best Doctors to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; and (b) to the extent expressly permitted by an applicable law, rule or regulation.
7. Internet Privacy
Best Doctors sees the Internet and the use of other technologies as valuable tools for communicating and interacting with consumers, employees, healthcare professionals, business partners, and others. Best Doctors recognizes the importance of maintaining the privacy of information collected and/or stored online and has systems in place that protect data collected and/or stored online or via an electronic database. Personal Information that is transferred from the EEA to the United States of America, will be treated in accordance with this policy.
8. Contact Information
Questions or comments regarding this Policy should be submitted to the Best Doctors Privacy Officer by mail or electronic means as follows:
Best Doctors, Inc.
100 Federal Street, 21st Floor
Boston, MA 02110 USA
FIRST EFFECTIVE DATE: 3 October 2007