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Privacy Notice

We are committed to protecting and respecting your privacy when dealing with your Personal Information. This privacy notice sets out the basis on which any Personal Information we collect from you, or that you provide to us, is used, stored, disclosed, and processed by us. Please read the following carefully to understand our practices regarding your Personal Information, how we will treat it and your rights in relation to that information. By providing your Personal Information to us or by using our services, website or other online or digital platform(s) you are accepting or consenting to the practices as described or referred to in this privacy notice.

When we refer to ‘we’, ‘us’ and ‘our’, we mean Life Healthcare Group (Pty) Limited and its subsidiary companies.

Your Personal Information

When we refer to Personal Information in this notice, we mean information relating to an identifiable, living, natural person, as defined in the Protection of Personal Information Act, 2013 ("POPIA"). We may hold and use Personal Information about you as a customer, supplier, employee, student, a patient or in any other capacity, in accordance with the relevant privacy and national health laws. Depending on what services you receive from us this may include Special Personal Information, as defined in POPIA, such as information relating to your health. The disclosure of your personal information to Life Healthcare is mandatory and required in terms of the services provided to you or agreements with you unless otherwise indicated as voluntary at the point of collection for example where consent is requested.

When do we collect Personal Information about you?

We may collect information about you when you:

  • are admitted as an in or out patient or register as customer with us or book to receive any of our diagnostic or complementary health services;
  • are referred by a doctor, or any other organisation for services;
  • visit one of our websites;
  • apply for a job with us and as part of the recruitment process;
  • enquire about any of our services;
  • use or request to use any of our online services;
  • fill in a form or survey for us;
  • carry out a transaction on our website;
  • participate in a competition or promotion or marketing activity;
  • make payments to us;
  • contact us, for example by email, telephone, or social media;
  • participate in interactive features on any of our websites;

Please note in the interests of training and continually improving our services, calls to Life Healthcare or any of its subsidiaries may be monitored or recorded.

Lawful Basis

To process your information in accordance with POPIA, we must establish a lawful basis for doing so which must be at least one of the following:

  • you consent to the processing of your information;
  • processing of the information is necessary for the performance of a contract or a legal obligation;
  • processing is necessary for the protection of our and your legitimate interests;

In addition, your Special Personal Information, such as information relating to your health may be processed if such processing is necessary for your proper treatment and care, for the administration of our professional practice or where such processing is necessary for the work conducted by insurance companies, medical schemes, medical scheme administrators and managed healthcare organisations.

The National Health Act, 2003 also permits us to disclose your Personal Information in the following circumstances:

  • you consent to this disclosure in writing;
  • a court order or any law requires that disclosure; or
  • non-disclosure of the information represents a serious threat to public health.

We process your Personal Information for a number of legitimate interests as set out within this privacy notice having assessed and taken into account your interests, rights, and freedoms.

The security and storage of your Personal Information

Your Personal Information will be kept confidential and secure and will, unless you agree otherwise, only be used for the purpose(s) for which it was collected and in accordance with this our applicable Privacy notice, POPIA and national health laws.

Organisational and Technical Security Measures

We have appropriate organisational and technical security measures in place to prevent unauthorized access or unlawful processing of Personal Information and to prevent Personal Information being lost, destroyed, or damaged. We monitor our information systems in an endeavor to ensure that the ongoing security is robust. All Personal Information you provide to us is stored securely. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our website and information systems, you are responsible for keeping that password confidential. We ask you not to share a password with anyone. The transmission of information via the internet cannot be guaranteed as completely secure. Once we have received your information, we will use strict procedures and security features in an endeavor to prevent unauthorised access.

At your own, or your doctor’s request, we may transfer personal information including health information to you or your doctor via email or instant messaging, specifically including, but not limited to WhatsApp, or you may choose to transfer information to us via email or instant messaging.

While this may be done for the purposes of providing you with appropriate treatment and care, these are not the most secure methods of information transmission; if you or your doctor choose to send or receive such information via these methods, you acknowledge and understand that the use, processing and sharing of your personal information in this manner will be done at your own risk.

Some of the risks which should be noted regarding the sharing of personal information through instant messaging platforms:

  • Instant messaging platforms are not monitored by the Life Healthcare security information office, as they are often sent and received on personally owned devices. We have no control over the security of instant messaging platforms or of the instant messages and information which is shared over these platforms;
  • Accountability for information sent from/to personal devices through instant messaging platforms becomes the responsibility of the recipient and sender in their own capacity as the platform is not owned, managed, or monitored by us;
  • The storage and back up of data on instant messaging platforms may occur in countries outside of South Africa until it is permanently deleted, resulting in personal information being processed outside of the borders of South Africa.”

IP Address

All information regarding your IP address will automatically be collected and stored as part of your access via the website to Life’s’ server. This website usage information serves as an indicator of how visitors of the website make use of the website, the amount of times which the website is accessed, the frequency of all users in general to each web page, registered IP addresses together with the time period of each visit and/or access of the website and web pages.

Should there be a security breach, the IP address will be used to identify the user by the internet service provider and contact will be made thereafter. Life endeavors to ensure that your IP address is not processed in a manner that infringes on your privacy.

Transfers of Personal Information outside of South Africa

Personal Information that we collect from you may be transferred to, and stored at, a destination outside of South Africa. It may also be processed by staff operating outside South Africa who work for us or for one of our suppliers. Where we transfer your Personal Information outside South Africa, we will endeavor to ensure that there are adequate protections in place for your rights, in accordance with POPIA. By submitting your Personal Information, and in providing any Personal Information to us, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Notice.

Disclosure of your Personal Information

We may disclose your Personal Information (to the extent necessary) to certain third party organisations used to support the delivery of our services during our usual course of business. These may include the following:

The hospital, clinic, facility, its staff and healthcare providers, including but not limited, to doctors, pathologists, radiologists and therapists (and other allied healthcare professionals or auxiliary medical professionals), may collect, process and disclose your confidential information, including information relating to diagnosis and treatment (referred to herein as “personal and health information” or “information”), as is necessary in the following circumstances:

  • to enable the hospital or clinical staff to perform their duties;
  • for the hospital, clinic, facility, its staff, and healthcare providers involved in your treatment, to provide the necessary services to you, for the purposes of your treatment and care. This will apply to services rendered to you during your current admission and any future admissions to any Life Healthcare hospital. This also includes services rendered by our pharmacy staff for the purposes of providing you with suitable pharmaceutical treatment and medicines in relation to your diagnosis and medical condition;
  • to facilitate the due and proper administration of the operations of Life Healthcare as a healthcare institution, in order to ensure that you, as our patient, receive quality healthcare;
  • to obtain authorisation for treatments and/or payment of your account from a medical scheme, other institution, person, or company.

In instances where Life Healthcare does share your personal and health information with third parties, Life Healthcare undertakes to share only those aspects of your information which is necessary, or which is necessary to prevent a threat to public health, while preserving the confidentiality, privacy, and security of that information as far as possible. In addition, Life Healthcare may be required to disclose your personal and health information in terms of a court order or other law. Upon your request, we will notify you of the recipients or category of recipients with whom we share your Personal Information, as well as the category of information shared (for example, your demographic or health information);

In addition to the above instances, you grant Life Healthcare the right to process your personal and health information, for the following purposes:

  • to share your information with our clinical engineering staff, third party clinical equipment suppliers and maintenance technicians to the extent that your information is stored or recorded on any of the clinical equipment used for the purposes of providing you with proper treatment and care. In these instances, we undertake to ensure the confidentiality, privacy, and security of your information as far as reasonably possible;
  • to share your information with third parties such as attorneys and other professionals acting on your behalf who may, on your instruction or with your knowledge and authorisation, seek access to your personal and health information for your benefit either for litigious or non-litigious reasons, or to share your information with our own attorneys and/ or other professionals for instituting or defending any potential legal and/or medico-legal claims and/ or evaluating any treatment;
  • to share your information with our relevant internal investigation team in the event that an incident related to your treatment occurs, as part of the hospital’s quality, internal complaints, and incident investigation process;
  • to share your information with non-clinical third parties such as our auditors, for the purposes of running and administering our dayto-day operations and subject to them being bound to confidentiality;
  • in respect of any outstanding hospital account, to share your information with third parties assisting us in recovering payment on the account from you (such as debt recovery agents or attorneys);
  • to share your Personal Information (limited only to your name and contact details) with our third party service providers for the purposes of conducting our post-discharge survey to ensure the ongoing quality of our services. In addition, should you choose not to participate in the post-discharge survey you may select to opt out of participating and we will cease from processing your information any further for these purposes;
  • to share your information with business partners, suppliers, and sub-contractors for the performance of services we provide to you as set out in the website privacy notice;
  • to share your information with organisations providing IT systems support and software development, and for hosting in relation to the IT systems on which your information is stored and subject to confidentiality undertakings;
  • to share your information with delivery companies for the purposes of transportation;
  • to share your information with third party service providers for the purposes of storage of information and confidential destruction;
  • to share your information third party marketing companies for the purpose of sending marketing emails, subject to obtaining appropriate consent;
  • Where a third party supplier is used, we shall endeavor to ensure that they operate under contractual restrictions with regard to confidentiality and security, in addition to their obligations under POPIA.
  • In the case of independent consultants, the consultant is the responsible party of your Personal Information, and will be required to maintain their own records in accordance with POPIA and applicable clinical confidential guidelines and retention periods;
  • Regulators: We may be requested – and in some cases can be required - to share certain information (including Personal Information and Special Personal Information) about you and your care with regulators such as the Department of Health, the Health Professions Council or the NICD. We will ensure that we do so within the framework of the law and with due respect to your privacy;
  • In an emergency and if you are incapacitated, we may also process your Personal Information (including Special Personal Information) or make Personal Information available to third parties on the basis of protecting your ‘vital interest’ (i.e., your life or your health);
  • We participate in national audits and initiatives to help ensure that patients are getting the best possible outcomes from their treatment and care. Confidentiality will be applied to your Personal Information in accordance with POPIA. Anonymous, pseudonymous, or aggregated information may be used by us, or disclosed to others;
  • We may also share your information with CareConnect and other members of the health information exchange (such as other healthcare providers and medical schemes involved in your treatment and care), for the purposes of the health information exchange (HIE) where you have provided us with your consent to do so.

Next of Kin

As a patient or guarantor, you may supply Life Healthcare with your next of kin’s personal information – this will only be processed where required to protect your legitimate interests or our legitimate business interests. It is your responsibility to ensure that your next of kin would not object to the provision and or processing of their Personal Information.

Sale of business

We may also disclose your Personal Information to third parties in the event that we sell or buy any business or assets or where we are required by law to do.

CCTV

Many of our premises are surveyed by CCTV for the purposes of security and the safe provision of care. Images and videos may be retained for a limited period.

Statistical and Research purposes

We may also retain your personal and health information for statistical, historical or research purposes. In such instances, we shall maintain the confidentiality of your information through adequate security measures such as de-identification or anonymisation of the information concerned.

Health Information Exchange (HIE)

We may process your personal and health information through the CareConnect health information exchange (HIE), but we will only do so once you or your legal guardian have signed a consent form to participate in the HIE. A more detailed consent and privacy notice relating to the Health Information Exchange will be made available to you at the point of consent.

Suppliers and Vendors

We may process your Personal Information as required for our legitimate business interests and in course of running our business. These include but are not limited to: during our BEE scoring and reporting process; computing sustainability measures; during quality audits; during internal and external investigations; if you submit tender and other proposals to us, and for vendor assessments that may be carried out as required. We may also process your information during a business due diligence; and we may process your information for commercial and market research purposes.

Your Rights

You have the following rights in relation to your Personal Information, where legally permissible:

  • Right of access: the right to make a written request for details of your Personal Information and a copy of that Personal Information;
  • Right to rectification: the right to have inaccurate information about you corrected or removed;
  • Right to erasure ('right to be forgotten'): the right to have certain Personal Information about you erased;
  • Right to restriction of processing: the right to request that your Personal Information is only used for restricted purposes;
  • Right to object: the right to object to processing of your Personal Information in cases where our processing is based on the performance of a task carried out in the public interest or we have let you know the processing is necessary for our or a third party’s legitimate interests;
  • Right to information portability: the right to ask for the Personal Information you have made available to us to be transferred to you or a third party in machine-readable formats;
  • Right to withdraw consent: the right to withdraw any consent you have previously given us to handle your Personal Information. If you withdraw your consent, this will not affect the lawfulness of our use of your Personal Information prior to the withdrawal of your consent and we will let you know if we will no longer be able to provide you your chosen product or service;
  • Right in relation to automated decisions: you have the right not to be subject to a decision based solely on automated processing which produces legal effects concerning you or similarly significantly affects you, unless it is necessary for entering into a contract with you, it is authorised by law, or you have given your explicit consent. We will let you know when such decisions are made, the lawful grounds we rely on and the rights you have.

Please note: Your rights are not absolute: they do not always apply in all cases, and we will let you know in our correspondence with you how and whether we will be able to comply with your request.

Should you, at any time, wish to object, or feel that we are not reasonably processing your personal and health information in a manner that preserves the confidentiality, privacy and security thereof as required by law, you may notify us accordingly, either telephonically or in writing, and we will then ensure that your complaint or query is investigated and dealt with efficiently. Further to the above, you may contact us in order to determine whether we hold any of your Personal Information and thereafter, to request that we rectify or delete such information (to the extent that we are not prohibited from doing so by any law), should it be found to be inaccurate or outdated. In this regard, you may access our PAIA Manual on our website, which outlines the manner and procedure in which you may request information from us.

Should you wish to exercise any of the above rights you may contact the Group Information Officer at myprivacy@lifehealthcare.co.za

Changes to our Privacy Notice

We keep our Privacy Policy under regular review and as a result it may be amended from time to time without notice. As a result, we encourage you to review this Privacy Policy regularly.

This privacy notice was last updated on 24 February 2022. All rights reserved.

Life Healthcare, Oxford Parks, Building 2, 203 Oxford Road (Corner Eastwood & Oxford Roads), Dunkeld, 2196