At Sims IVF we understand how important privacy and security of information is to our patients. We do our utmost to safeguard your personal data, and ensure you feel confident and secure in the protection afforded to you and your personal information.
For the purpose of Data Protection Regulations, Sims IVF, with a registered address at Barrow Street, Dublin 4 and registered under company number 280514 is the Data Controller with responsibility for the management of patient and staff data in compliance with current Irish and European law.
The types of information we collect about you
In order to deliver safe and effective treatment, and in order to comply with European laws relating to the provision of fertility treatment, we collect certain personal data from our patients. Personal data refers to information that is, or could be, identifiable to you.
We may collect, or ask you to provide the following personal data;
Our new patient form will ask you to provide your name, date of birth, gender, address, PPS number, health insurance information, and contact details (including email address and phone number). If you do not want Sims IVF to contact you in a certain way please let us know, or do not provide that contact information.
You will be asked to take a photo at initial consultation. This is to allow staff to perform visual confirmation of identification. The photo is only visible to staff members when they access your chart and is only used for identification purposes.
It may also include images recorded on our CCTV cameras during the course of your appointments.
This may be required when you make a payment to us by credit card or electronic transfer.
A medical record is created for each medical, nursing or laboratory procedure, and saved to your electronic patient chart. These records may also include ultrasound images, test results and consultation notes.
You will be asked to provide contact information for your GP if you are happy for us to communicate with them.
All contact you have with the clinic is recorded in your medical record. An entry is recorded into your electronic chart for every phone call, email or any communication between you and Sims IVF. Emails and phone call recordings may also be retained for certain periods of time
This information may include patient satisfaction surveys you have completed, verbal communication to a staff member, or a complaint. It also includes comments made in relation to our online presence.
Where do we collect this personal data?
Most personal information collected will be requested directly from you, with your consent.
We also receive data such as test results from third party facilities who have completed testing on our behalf.
For certain treatments we work with partner clinics, who may send us data in relation to your treatment cycle.
If you are attending the clinic with a partner they may have provided us with certain details, such as your name, address, gender, date of birth, contact details, relationship to them, and PPS Number.
Why do we collect your personal data?
Our goal is to deliver the best possible care to all of our patients. The information gathered and stored by Sims IVF is used;
- To ensure our clinicians and staff have all information necessary to advise you of the best course of treatment
- To ensure a detailed and complete record of your treatment at Sims IVF is available for you and the medical staff.
- To facilitate easy communication with you regarding the administrative aspects of care; invoices, statements, etc.
- To meet the legal requirements established under the EU Tissue and Cell Directive 2004/23/EC to maintain records of donated materials.
- To ensure that content from our Site is presented in the most effective manner for you and for your computer.
- To carry out verification and statistical analysis
- To contact you, if required, in relation to a service you request or to respond to your communication to us.
- To carry out our obligations arising from any contracts entered into between you and us and other administrative purposes.
- To allow you to participate in interactive features of our service, when you choose to do so.
- To notify you about changes to our service.
- To carry out medical research and training for educational purposes. Your information used for this purpose will always be anonymized.
Management of you Personal Data
Who do we share your personal information with?
We may share your personal data with our selected business associates, suppliers and contractors to provide you with our services. For example, these business partners may include:
- Testing facilities or healthcare providers that require your personal data as part of the provision of medical treatment;
- Service providers that have access to our data as a necessary and controlled part of the provision of service
- Regulatory bodies such as the HPRA, where we are obliged to make data available as required
- We are on occasion required to share certain information with our parent company and their representatives, insurers and legal advisors, and obliged by law to disclose information to a regulatory body, or due to legal obligation. Only necessary information will be disclosed, all parties will be keep the information confidential
How long do we retain your information for?
The EU Tissue and Cell Directive 2004/23/EC requires that records relating to the collection, storage, and use of tissues and cells are maintained for a period of thirty years. If you engage in a treatment cycle data must be retained by law for that period.
Call recordings are retained for a period of 3 months. The length of time that other data is maintained in outlined in our Data Retention Policy. For further information on the periods for which your personal data is kept, please see our data retention policy, a copy of which can be made available on request to our Data Protection Officer.
Permission to Use your Personal Data
There are different types of permission necessary for the various uses of your personal data;
- It’s necessary in order to deliver the treatment and/or services you have requested from us.
- You have provided consent for the processing for one or more specified purposes, e.g. treatment
- It’s required by regulatory bodies
- It’s required by our parent company, for the purposes of reporting risk or insurance matters.
- It is necessary as part of legal claims
Sending data outside the European Union (EU) or European Economic Area (EEA)
For certain treatment programmes it may be necessary to send data to healthcare professionals/ laboratories operating outside of the EU or EEA. You will be advised in advance that this disclosure of data is required, and asked to provide consent for the same transfer.
Sims IVF is part of parent Company based in Australia. On some occasions it may be necessary to share data with them or their representatives for the purposes of risk management and insurance purposes.
In all cases where data is to be sent outside the EU or EEA Sims IVF will ensure data processing agreements are in place to protect your information and privacy.
The personal data that we collect from you may be transferred to and stored at a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the processing of your request for information and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. Sims IVF will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Statement.Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Site; any transmission is entirely at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
What are your rights in relation to your personal data?
You have the following rights:
- To access a copy of personal data we hold about you;
- To have us correct any inaccurate personal data about you without undue delay;
- To erasure of personal data we hold about you. Please note, this right is limited to specific situations, and cannot be completed where there are legal requirements that we retain the information
- To request a copy of your personal data in a portable format.
- To request a restriction of the processing of your personal data.
- To withdraw consent for processing of data at any time in advance of processing. Any processing that occurred before you withdrew your consent remains lawful.
We may, from time to time, provide links to third party websites. In addition, third parties websites may also provide links to the Site. Should you choose to visit these third party websites, you should review their privacy policies to ensure you understand and are comfortable with their practices concerning your personal information. We do not accept, and do disclaim, any responsibility for the privacy policies and information protection practices of any third party website (whether or not such site is linked on or to the Site). These links are provided to you for convenience purposes only, and you access them at your own risk. Please check these policies before you submit any personal data to these websites.
We may obtain information about your general internet usage by using cookies.
What is a Cookie?
A cookie is a small data file implanted by our Site on your device (e.g. your phone or your computer) which collects information including your personal information about you. For instance, when you return to the Site after logging in, cookies provide information to the Site so that the Site will remember you. They help us to improve our Site and to deliver a better and more personalised service. How to Manage and Disable Cookies
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your web browser settings. Each browser is a little different, so look at your browser “Help menu” to learn the correct way to modify your cookies. If you turn cookies off, you won’t have access to many features that may make your browsing of the Site smoother and some of our services may not function properly.
Types of Cookies Used
The following are the various types of cookies used on the Site.
These cookies are essential in order to enable you to navigate the Sites and use the Sites’ features, such as accessing secure areas of the Site. Without these cookies, services you have asked for cannot be provided.
These cookies allow the Site to remember choices you make and provide more personal features. These cookies can also be used to monitor and analyze the performance, operation and effectiveness of the Site, so that we can improve and optimize it.
We may also use session cookies, which are temporary cookies that aid your navigation through the pages on the Site, and will remember preferences you have selected during the session. These cookies expire once you close your browser.
These cookies collect information about how you use the Site, for instance which pages of the Site you most often use. The information collected by these cookies does not identify you. All information these cookies collect is aggregated and therefore anonymous.
We use Google Analytics to help monitor and analyse use of the Site. Google Analytics is a type of performance cookie which collects standard internet log information and visitor behaviour information in an anonymous form. The information collected by this cookie is transmitted to Google who then used it to evaluate visitors’ use of the Site and to compile statistical reports on Site activity. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
For more information on cookies please visit www.aboutcookies.org
Other Technologies Used to Collect Data
The Site may also use other technical methods to track visitor usage, including web beacons. (‘Web beacons’ are small pieces of data that are embedded in images on the pages of a website.) We may also use these technical methods in HTML e-mails that we send visitors to the Site to determine whether such visitors have opened those e-mails and/or clicked on links in those e-mails. We may collect the information from use of these technical methods in a form that is personally identifiable.
Changes to our Privacy Statement
Queries and Complaints
If you have any queries or concerns you can contact our Data Protection Officer
Address: The Data Protection Officer, Sims IVF, Clonskeagh Road, Clonskeagh, Dublin 14
You can make a complaint to Data Protection Commission in relation to our processing of your personal data.
Office of the Data Protection Commissioner
Telephone: +353 (0)761 104 800 or Lo Call Number 1890 252 231
For further information please visit www.dataprotection.ie