Patient Data Protection & Privacy

Who we are and how to contact us

Bon Secours Health System CLG ("Bon Secours") is a private hospital group.

For further information or queries about your data and your data protection rights, please contact

Data Protection Officer,

Bon Secours Health System,

Bon Secours Group Offices, 7 Riverwalk,

Citywest,

Dublin 24,

D24 H2CE.

Phone: 01 685 4474, email: dpo@bonsecours.ie

How your personal data is used and the legal basis for its processing

We process your personal data for medical purposes to provide healthcare services to you, on the basis of your contract with Bon Secours or, for patients being treated under the National Treatment Purchase Fund (NTPF) scheme, the performance by the NTPF of its functions and responsibilities under legislation. Medical purposes include medical diagnosis, treatment and further management, preventive medicine and the provision of healthcare services, including audit and quality improvement.

In general, your data may only be processed for medical research purposes on the basis of your informed and explicit consent. However, there are limited circumstances in which your data may be used for medical research or public health purposes without your consent. Examples would include our legal obligation to provide patient data to the National Cancer Registry, or the Health Protection Surveillance Centre.

Data collected about you

To provide treatment to you, Bon Secours needs to process your medical records and related personal information, such as your address and other contact details.

How your personal data is collected

We obtain your personal data directly from you in the course of your diagnosis and treatment. We may also be provided with information necessary for your treatment by other healthcare providers, such as your GP or other hospitals which have been involved in your care and treatment.

How your personal data is disclosed

Your data will be provided as necessary for medical purposes to those involved in your treatment and care including, where applicable, other hospitals or your health insurer. Medical consultants practicing at Bon Secours are independent medical practitioners and not employees of the hospitals. As such, to the extent that they need to process your personal data in the course of their professional activities, they are joint controllers of your data with Bon Secours.

Your data may also be disclosed where required or authorised by law, for example, for medical research or public health purposes.

International transfers

Bon Secours, as part of Bon Secours Mercy Health International headquartered in the U.S.A., may from time to time use business partners and service providers located outside of the European Union to process patient data. When this is done, at least one of the following safeguards to protect your personal data to a similar level as within Europe will be applied, i.e.:

• We will use service providers located in countries which have been designated by the European Commission as having an adequate national standard of data protection, or;

• For transfers to the United States of America, our partners or service providers may be registered under and have committed to adhering to the Privacy Shield Framework , or;

• We will require our partners or service providers to adopt the standard data protection contract clauses pre-approved by the European Commission.

Data retention

We will only retain your personal data for as long as is necessary to fulfil the medical purposes for which it is recorded, including any legal or regulatory requirements to maintain records.

Your Data Protection rights

• You have the right to be provided on request with a copy of your personal data. For requests for health related data, we are obliged to consult with the appropriate health practitioner (normally, your treating clinician) to ensure providing the data to you will not result in serious harm to your physical or mental health.

• You have the right to rectification of inaccurate data we may have recorded about you.

• You have the right to the erasure of your data ("right to be forgotten") which we no longer have justification for recording.

• You have the right to object to processing of your data which is being done by Bon Secours on the basis of its legitimate interests.

• You have the right to restrict the processing of your personal data when:

  • the basis for its processing is in dispute;

  • its accuracy is in dispute;

  • we cannot establish a lawful basis for its processing, but you do not wish it to be erased;

  • we no longer need your data, but you need it for the establishment, exercise, or defence of legal claims;

  • you object, where applicable, to our processing of your data on the basis of our legitimate interests, pending verification of whether your interests override ours.

• You have the right to be provided with a copy of your electronic data records in machine readable format, or to have them transferred directly to another data controller ("data portability").

If you are not satisfied with our responses or are otherwise concerned with how we process your personal data, you also have the right to make a complaint to the Data Protection Commission.

How Can I Access My Medical Records?

Patients can request their own personal health records or the records of a dependant by contacting us directly. We encourage requesters to contact the relevant hospital Department to ensure that the correct information is given and to narrow the field of enquiry. Contact details are shown in the table below.

Bon Secours Data Protection Representatives (DPR):

 

For your convenience and in the interests of processing your request more efficiently we have provided a form that you can complete and send to the relevant hospital as per the table above. This is available using a link at the bottom of this page.