Data Protection
Beacon Hospital provides exceptional patient care with dedicated teams of highly skilled compassionate professionals. Enabled by our world leading technologies and equipment Beacon Hospital is committed to providing excellent patient care.
Beacon Hospital processes personal data of patients and staff members in order to provide this care. This Privacy Policy outlines the details of the types of data we collect and the responsibilities of Beacon Hospital in how we collect, use, store and protect the data we collect to support patient care. This policy will also outline your rights as a data subject in accessing your data.
Introduction to Data Protection
Personal data generally means information that can identify a person.
Data processing means actions that can be performed in connection with personal data such as collection, use, storage and disclosure of that data.
Data Controller determines the purposes and means of processing data in other words the “How and why” of processing data.
In this case, the data controller is Beacon Hospital Sandyford Limited (“Beacon Hospital”),
Beacon Hospital
Sandyford, Dublin 18, D18 AK68.
Beacon Hospital processes your personal data across a range of systems and tools including an Electronic Health Record, CCTV, Device registers and Health registry data.
Data Protection at Beacon Hospital
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What legislation supports how Beacon Hospital manages my data?
All personal data collected, processed and stored in Beacon Hospital is done so in accordance with EU General Data Protection Regulation of 2018 (GDPR).
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Why does Beacon Hospital process my data?
Data Processing Activity Description Lawful basis under the GDPR Pre-visit Data Collection / General Admission Form We receive your personal data and medical history prior to your visit in the form of a referral from your GP or referring consultant. If you are self-referring to Beacon Hospital, your personal data and medical history will be collected at your first visit. We rely on the provision of healthcare (Article 9(2)(h)) and consent (Article 6(1)(a)) GDPR to schedule your hospital visits and to ensure your team can prepare for your visit and plan your care. Admission Booking Form If you require a visit to the hospital for a procedure or admission we collect data from you and your consultant regarding your medical assessment, requirements for procedure and admission as well as relevant insurance details. We rely on the provision of healthcare (Article 9(2)(h)) and consent (Article 6(1)(a) GDPR) to plan your care during your procedure or admission –to support the contract of delivery of care between you and Beacon Hospital. Insurance and Payment Details We will collect details of your health insurance or other relevant payment details if your care is be covered by a third party such as an employer or sports team. Your information will be shared with your insurers or relevant third party as consented by you in your insurance policy documents and the General Admission Form as signed by you. We rely on the provision of healthcare (Article 9(2)(h)) and contractual necessity (Article 6(1)(b) GDPR) to support the performance of contract of delivery of care between you and Beacon Hospital. Documentation of your care during your Visit Your team will document the clinical details of your care in the hospital medical record. This may require documentation across paper and electronic systems correct for the specialty you are attending. We rely on the provision of healthcare (Article 9(2)(h)) and contractual necessity (Article 6(1)(b) GDPR) to support the provision of exceptional, safe care under the contract of delivery of care between you and Beacon Hospital. Prescriptions and Medication Orders Your team will prescribe and administer the medications you require during your visit based on the information collected in your medical record. They may also gather additional data from your GP or local pharmacists. We rely on the provision of healthcare (Article 9(2)(h)) and contractual necessity (Article 6(1)(b) GDPR) to support the provision of exceptional, safe care under the contract of delivery of care between you and Beacon Hospital. Diagnostic Testing including Imaging and Pathology Your team will request, report and analyse diagnostic tests using Beacon Hospital medical records. If required for safe clinical care your team may request reference test results from other hospitals or you GP. We rely on the provision of healthcare (Article 9(2)(h)) and contractual necessity (Article 6(1)(b) GDPR) to support the provision of exceptional, safe care under the contract of delivery of care between you and Beacon Hospital. Discharge Documentation and Prescription On completion of your visit your team will issue discharge documentation to you and the person who referred you to Beacon Hospital. With your consent your team may also share your discharge documentation and referrals for post discharge care to relevant community and third party services. We rely on the provision of healthcare (Article 9(2)(h)) and contractual necessity (Article 6(1)(b) GDPR) to ensure safe discharge process and continuity of care after your visit to Beacon Hospital, under the contract of delivery care between you and Beacon Hospital. Multi-Disciplinary Team Meetings Your team may discuss your case with external multi-disciplinary specialists in order to form a peer reviewed plan of care. We rely on the provision of healthcare (Article 9(2)(h)) and [contractual necessity Article 6(1)(b) GDPR)] to support the provision of exceptional, safe care under the contract of delivery of care between you and Beacon Hospital in compliance with National Best Practice guidelines. (NCCP 2016/2026) Reporting Infectious Diseases Beacon Hospital Infection Prevention and Control team is required to report communicable diseases to the Medical Officer of Health / Health Protection Surveillance Centre. For more information see www.hpsc.ie/notifiablediseases/ We rely on provision of healthcare (Article 9(2)(h)), legal obligation (Article 6(1)(c) GDPR) as required for public health in accordance with S.I. No. 390/1981 Infections Diseases Regulations 1981 www.hse.ie/eng/services/list/5/publichealth
National Hemovigilance Office Beacon Hospital is required to report any serious adverse reactions, events or near miss events involving blood products to the NHO. We rely on the provision and management of healthcare system (Article 9(2)(h)) and legal obligation (Article 6(1)(c) GDPR) to ensure high quality, safe practice associated with blood products in line with National and EU legislation S.I. No. 360 of 2005 and S.I. No. 547 of 2006.
CCTV Beacon Hospital operates CCTV across all hospital departments in order to protect patients, staff and property. We rely on legitimate interest (Article 6(1)(f)) of the healthcare provider to ensure safety and security of the premises and its visitors. Registration and Monitoring of Implantable Devices Some implantable cardiac devices are registered and monitored by external providers. This will be discussed with you during the process of your assessment for your device. We rely on explicit consent (Article 9(2)(a) and Article 6(1)(a) GDPR) in order to monitor your device and register the device that you have. Incident Reporting and Complaint Management When investigating a patient safety incident or complaint your personal data will be used to investigate the incident or complaint. We may also use this data to report incidents to An Garda Síochána and/or Tusla. We rely on provision and management of healthcare (Article 9(2)(h) and legitimate interests of the Hospital to defend itself in respect of a legal claim (Article 6(1)(f) GDPR) to ensure patient safety and quality of care. Dictation Services Your personal data is shared securely with third party dictation services in order to generate timely reports / correspondence of your visit to Beacon Hospital. We rely on the management of healthcare system (Article 9(2)(h) and legitimate interests (Article 6(1)(f)) GDPR to enable efficiency of day-to-day operations and support the provision of exceptional, safe care under the contract of delivery of care between you and Beacon Hospital Beacon Hospital is committed to Audit, Quality Assurance and Accreditation. The use of data to support these activities is done in an anonymised aggregated format with personal identifiers removed.
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How does Beacon Hospital obtain my data?
With your consent, you as a patient are the main source of information about your care. When you attend the hospital for an appointment our patient services team will ask you to confirm your name, address, date of birth as well as the details for your GP. The healthcare team involved in your care will ask you for information about your medical history, the reason for your current visit to Beacon Hospital, what medications you take regularly as well as other information that may be helpful in completing your medical assessment. Your other care providers, for example your GP, community services or another hospital may send your personal data to Beacon Hospital as part of a referral or to assist in the completion of your medical assessment.
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How long does Beacon Hospital keep my data for?
Beacon Hospital holds your personal data on our secure systems for 8 years after the death of the patient. This is in order to ensure our healthcare teams have the necessary information available to provide your care when required, comply with statutory retention periods, handle complaints, and management and defence of legal claims.
Personal data captured on CCTV is held for 30 days.
Personal data related to defence of legal claims is held for 10 years after the date of closure of the claim.
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Does Beacon Hospital share my personal and medical data?
Beacon Hospital may share your personal and medical information with health professionals involved in your care. Your information may be shared with
- Community and General Practitioner services in order to ensure continuity of care when you leave Beacon Hospital.
- Other healthcare institutions or hospitals should your care be transferred to another provider or for the purpose of Multi-Disciplinary Team meeting discussion.
- Diagnostic companies for the completion of laboratory testing.
- Care providers for the provision of specialist equipment and treatment.
- Insurance companies. Beacon Hospital is required to send patient details as necessary to the insurance companies in order to process your insurance claim. When you register for our visit in Beacon Hospital you are asked to sign the insurance declaration. This explains that if you provide valid Health insurance membership details, Beacon Hospital will share this information with your insurer in order to process your insurance claim. Often an insurance company will request an audit of claims paid. Beacon Hospital will supply only the information for that claim once received in writing from the insurance company.
- Consultants billing / secretaries. Beacon Hospital will send patient details to the consultants billing company or secretaries as requested in order to complete a claim. Beacon Hospital send only information necessary to process that claim.
- Research seeks to investigate new treatments, interventions and management procedures so that patient care is continually improved. Your information could be used for research and shared with research partners but only
- When anonymised or
- With your specific consent.
- Legal requirements. In certain circumstances; Beacon Hospital is required by law to report information to the appropriate authorities. This information is often provided after authority has been given by a qualified health professional. For example:
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- Where we encounter infectious diseases which by law, Beacon Hospital are required to notify to the Health Protection Surveillance Centre.
- Where a formal court order has been issued.
- In the event of a child protection concern Beacon Hospital will share relevant information with Tusla.
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Is my data shared outside of the EEA?
Beacon Hospital may transfer personal data outside the EEA for example in the case of a research project. Where Beacon Hospital is transferring personal data to a jurisdiction that has not been deemed adequate by the EU, the transfer is conducted on the basis of Standard Contractual Clauses. In respect of transfers to the US and where the recipient participates in the Data Privacy Framework, the Data Privacy Framework will be relied upon.
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Your rights as Data Subject
Subject to applicable laws and requirements, you have the right to:
- Be fully informed on why we are collecting your information and how we are using it (i.e., through the information provided in this Policy).
- Object to Beacon Hospital using your personal data where the processing is conducted on the lawful basis of legitimate interest or public interest.
- To have inaccurate information about you corrected.
- Request a copy of personal data relating to you
- Complain to the Data Protection Commissioner as Beacon Hospital’s supervisory authority. We ask that you first engage with Beacon Hospital to provide us with the opportunity to address any concerns
- Withdraw consent to processing based on consent. Such withdrawal of consent shall not affect the lawfulness of processing conducted on the basis of consent prior to its withdrawal.
Data subjects may contact the DPO ([email protected]) to exercise any of their data subject rights. Please see below on how to exercise a data access request.
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Right to Obtain a Copy of your Personal Data
Subject to applicable laws, under the GDPR, you have a right to obtain a copy, of any personal data relating to you.
A request for access to personal data (including medical records) can only be made by you (the patient), or a person you authorise such as a family member, next of kin or your solicitor.
To request a copy of your Personal Data:
- You can contact our medical records team either by email at [email protected] or by letter to Data Request, Beacon Hospital, Beacon Court, Sandyford, D18 AK68.
- Supply relevant information to confirm records requested (for example if you request your complete medical record or your most recent scan result).
- Include legal name, date of birth and the date you attended the hospital.
- In certain circumstances in order to verify your identity, we may request appropriate identification, for example Current Irish Driver’s License, Valid Passport. This is to make sure that personal information is not given to the wrong person.
Once you have made your request, you must be given the information within 1 month.
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Delivery
Your records can be sent by secure email or can be sent by registered post. If you chose to collect your records from the hospital this can also be arranged. We do require proof of identification when records are collected.
Data Protection officer
Beacon Hospital’s Data Protection officer can be contacted via email [email protected] or via telephone 01 650 4646 or by post addressed to:
Data Protection Officer
Beacon Hospital
Sandyford
Dublin 18
D18 AK68