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Introduction to GDPR

Children's Health Ireland at Crumlin understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our service users and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the GDPR.

All Personal data we gather will be “processed” in accordance with all applicable data protection laws including the EU General Data Protection Regulation (“GDPR”) and the applicable Irish Data Protection Acts.

For the purposes of the GDPR Children's Health Ireland at Crumlin is a “Data Controller” registered with the Data Protection Commission.

1.      What Does This Privacy Statement Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

2.      What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 4, below.

3.      What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

(a)    The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 12.

(b)    The right to access the personal data hold about you. Part 10 will tell you how to do this.

(c)     The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 12 to find out more.

(d)    The right to erasure, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have, where there is no compelling reason to continue processing. This right only applies in certain circumstances, it is not a guaranteed or absolute right. Please contact us using the details in Part 12 to find out more.

(e)    The right to restrict (i.e. prevent) the processing of your personal data.

(f)     The right to object to us using your personal data for a particular purpose or purposes.

(g)    The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

(h)    Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 12.

Further information about your rights can also be obtained from the Data Protection Commission.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Data Protection Commission.

4.      What Personal Data Do You Collect?

To allow us to provide services to you, we collect and process various categories of personal information.

We may collect some or all of the following personal data (this may vary according to your relationship with us):

- Personal details about you, your child, address, your child’s date of birth, contact details (mobile phone number), next of kin

- Notes and reports about your child’s health needs

- Results of investigations, such as X-Rays and laboratory tests

- Relevant information from other health and social care professionals, your child’s carers or relatives

- CCTV footage images

We may also process certain special category data which will include health information, racial or ethnic origin, religious or philosophical beliefs, genetic and biometric data.

5.      How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary to protect your vital interests and for our performance of a contract with you, because you have consented to our use of your personal data, or processing is necessary for tasks carried out in the public interest or in the exercise of an official authority vested in the hospital in this instance the Health Act 2007.

The Hospital’s lawful basis for processing personal data of service users is as follows:

1. The processing is necessary in order to protect the vital interests of the person (referred to as the data subject in Data Protection language). This would apply in emergency situations such as in the Emergency Department

2. The processing is necessary for a task carried out in the public interest or in the exercise of official authority vested in the controller; for the HSE this official authority is vested in us through the Health Act 2004 (as amended).

Special categories of data are defined by the GDPR and include things like racial or ethnic origin, religious or philosophical beliefs, genetic data, biometric data, health data, sex life details and sexual orientation.

We only process special categories of personal data where it is necessary;

- for the purposes of preventative or occupational medicine

- for the provision of healthcare, treatment or social care

- for the management of health or social care systems and services, or

- pursuant to a contract with a health professional.

If the purpose of the processing is for a reason other than the reasons above, we will seek explicit consent to process your sensitive personal data (referred to as ‘special categories’ of data under the GDPR).

Your personal data may be used for one of the following purposes:

- Review the care we provide for you to ensure it is of the highest standard

- Investigate complaints, legal claims or adverse incidents

- Protect wider public health interests

- Provide information for planning so we can meet future needs for health and social care services

- Provide information to prepare statistics on Health Service performance

- Provide training and development

- Remind you of appointments by text

6.      How we obtain your personal data?

We may obtain your information from a variety of sources, including information you give to us. We may also receive your personal information from third parties, for example your GP, your dentist, your social worker, or pharmacist.

7.      How do you keep my data secure and confidential?

We are committed to ensuring that your information is secure with us and with the third parties who act on our behalf. We have a number of security precautions in place to prevent the loss, misuse or alteration of your information. All staff working for the hospital have a legal duty to keep information about you confidential and all staff are trained in information security and confidentiality. The hospital has strict information security policies and procedures in place to ensure that information about you is safe, whether it is held in paper or electronic format.

8.      How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.

9.      How and Where Do You Store or Transfer My Personal Data?

We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the EEA and under the GDPR as follows.

We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts ensure the same levels of personal data protection that would apply under the GDPR.

10.   Do You Share My Personal Data?

We may share your personal data with selected third parties such as suppliers and contractors. In some cases, those third parties may require access to some or all of your personal data that we hold. These may include:

- health insurers to secure payment for your treatment where it is covered by your private health insurance policy;

- health professionals, independent consultants and other hospitals that require your personal data as part of the provision of medical treatment;

- IT service providers that either host or have access to our data as part of their product offering;

- regulatory bodies such as HIQA and the Health and Safety Authority, where we are obliged to make data available as required;

- outsourced service providers such as the use of external laboratories;

- other companies and organisations with whom we exchange data for the purposes of fraud protection and credit risk reduction including debt collect agencies.

- audit and quality assurance bodies or registries for quality assurance processes and service evaluation

We are required to provide statistical information to the HSE and Department of Health. We will make sure that you cannot be identified by anonymising the information. If it is not possible to anonymise the information, you will be contacted for your consent for your child.

We may also be receiving services from providers outside of the hospital, for example, referral services. In order to assist in this process, we may need to share your personal information with those providers. We are careful only to share the information that is necessary for this purpose. Anyone who receives this information is also bound by confidentiality and the data protection laws. In certain situations, we may have to disclose your personal information to other agencies, in accordance with legal requirements, i.e. Dept. of Social welfare, Department of Health, the Courts etc., or in an emergency situation to prevent injury to other persons.

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, obligations, and the third party’s obligations under the law.

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the EEA and under the GDPR, as explained above in Part 9.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

11.     How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 12. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within a month. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

12.    How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

CHI at Crumlin
Alan McKenna
Site Data Protection Officer
Email: dpo@olchc.ie
Telephone: +353 1 409 6100

CHI at Temple Street
Alan McKenna
Site Data Protection Officer
Email: dpo@cuh.ie
Telephone: +353 1 878 4200

CHI at Tallaght
Trevor Murphy
CHI Data Protection Officer
Email: hrd@nchg.ie
Telephone: +353 1 409 6100

CHI at Connolly
Trevor Murphy
CHI Data Protection Officer
Email: hrd@nchg.ie
Telephone: +353 1 878 4200

13.    Changes to this Privacy Statement

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our practices in a way that affects personal data protection.