Privacy matters to Iwosan Lagoon Hospitals Limited (IWLH or the “Hospital”), so we follow a privacy framework that helps us to manage and protect your information in our medical services, products, and websites. Whether you are new to the hospital or a long-time user, please take the time to get to know our practices – and if you have any questions contact us. This Privacy Notice (“Notice”) describes how we collect, use, store, handle and secure personal information (sometimes referred to as “Personal Information”, “Personally Identifiable Information” or “PII) because the Hospital is dedicated to protecting the confidentiality and privacy of information entrusted to us by staff, patients, customers and all stakeholders. This privacy notice sets out our current policies and demonstrates our commitment to privacy.
Iwosan Lagoon Hospital is a pioneer in the field of Healthcare in Nigeria running a chain of Multi-Specialty Hospitals and other healthcare facilities in Nigeria, provides Healthcare Services through its hospitals, owned and managed at various locations in Nigeria and offers Diagnostic, Investigations, Consultation/Opinion, Nursing & Pharmacological, Counselling, Procedural & Surgical Treatment, Dietary Service and other Emergency Services. Our privacy/personal data protection principles are applied based on this Privacy Notice at all relevant locations where hosting and processing takes place. Our Privacy Notice may be updated from time to time, but such update would be reflected on our website. It is accepted that your continued use of our online platforms will mean that you agree to the changes.
PRIVACY NOTICE – SCOPE
Our Data Protection Policy including this Privacy Notice applies to personal information processed by the Hospital as a data controller and as described in this Notice. The Data Protection Policy including this Notice explains what information we collect about our customers, how we use that information, who we share it with, the circumstances under which we may share it and what steps are taken to make sure it stays private and secure. The policy also clearly outlines the right of customers in respect of information collected in the course of business.
It is important to know that the policy continues to apply notwithstanding the fact that the agreement between IWLH and the party using our services ends. It covers every and any service which customers (Private, Corporate, HMO) have with IWLH.
COLLECTION AND USE OF PERSONAL INFORMATION
WHAT WE COLLECT
IWLH obtains personal information about you if you choose to provide it — for example, to fulfill your request and to provide the requested and / or agreed services. By submitting personal information to IWLH, you are also acknowledging that IWLH may use this information in accordance with its Data Protection Policy including this Notice.
Your personal information is not used for purposes other than those listed in this document, unless we obtain your permission, or unless otherwise required by law. In general, we collect and generate the following categories of information:
Type of Personal data
Such as name, surname, ID card number, face image, gender, date of birth, passport number or other identifiable numbers, Closed circuit television (CCTV) in and around IWLH facilities (these may collect photos or videos of you).
Such as address, telephone number, e-mail address
Such as billing information, credit or debit information, receipt information, invoice information
Such as registration information used for subscribe and marketing participation, details of the services we offer and your preferences
Such as IP Address of computer, type of browser, Cookies information time zone setting, operating system, platform and technology of devices used for accessing website and Online Appointment System
such as treatment information, reports about physical or mental health condition, health cares of service receivers, laboratory test results, diagnosis, diagnostic disease, information about drug use and drug allergy, history of food allergy, blood result, laboratory result, pathological result, radiological images and radiological report, list of prescribed medication, necessary information for medical services, information of feedback and treatments
SOURCES OF PERSONAL DATA
IWLH collects and gathers your personal data from the following sources
- Persons who are close to you such as relatives, spouse etc.
- Persons you give authority to act on your behalf in contact with the hospital
- Network health providers, in case you already give consent to the network health provider for disclose of your personal data
- Person, juristic person or agency of any government, private sector, or state enterprise who refers you for investigation services to IWLH or is a payer for your service expense
WHY WE COLLECT IT AND THE LEGAL GROUNDS
IWLH generally collects only the personal information necessary to fulfill your request and to provide the requested and/or agreed services. Where additional, optional information is sought, you will be notified of this at the point of collection. The applicable law allows us to process personal information, so long as we have a ground under the law to do so. It also requires us to tell you what those grounds are. As a result, when we process your personal information, we will rely on one of the following processing conditions:
- Performance of a contract: This is when the processing of your personal information is necessary in order to perform our obligations under a contract but also to be able to complete our acceptance procedure so as to enter into a contract;
- Legal obligation or for public interest: This is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for complying with any tax obligations, regulatory purposes, or providing information to a public body or law enforcement organization;
- Legitimate interests: where necessary, we may process information about you where there is a legitimate interest for us or a third party with respect to your health interests, except where such interests are overridden by your interests, fundamental rights and freedoms; or you expressly deny.
- Consent: We may occasionally ask you for specific permission to process some of your personal information for some or more specific purposes such as research and studies, and we will only process your personal information in this way if you so agree.
- What constitutes consent? Your consent is given when you consume our services, navigate our website, tick our online forms or boxes, subscribe to our email alerts, and attend our online/offline events and other events, or when you voluntarily submit your personal data to us.
- How do you withdraw your consent? You may withdraw your consent at any time by unsubscribing to our email alerts or other digital platforms or by contacting the IWLH’s Data Protection Officer (DPO) via firstname.lastname@example.org
RETENTION OF INFORMATION
We retain your personal information for as long as we have a relationship with you, subject to applicable laws and regulation. When deciding how long to keep your personal information, we consider our legal and regulatory obligations and internal personal information management policies. For example, we retain records to investigate or defend against potential legal claims or where required by law. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law. Conversely, we will only retain your personal data for as long as or until such a time that you request and/or exercise your right to deletion/destruction.
STORAGE AND SECURITY OF INFORMATION
We implement and maintain organizational, technical, and administrative security measures designed to safeguard the information we process within our organization against unauthorized access, destruction, loss, alteration, or misuse. These measures are aimed at providing on-going integrity and confidentiality for your personal information. We evaluate and update these measures on an ongoing basis. Your information is only accessible to personnel who need access to the information to perform their duties, However, while we take precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.
We do not share personal information with unaffiliated third parties, except if necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law. These include:
Service providers: IWLH works with reputable partners and service providers so they can process your personal information on our behalf where required. IWLH will only transfer personal information to them when they meet our standards set in our policy on the processing of data and security. We only share personal information that allows them to provide their services.
Courts, law enforcement or regulatory bodies: IWLH may disclose personal information in order to respond to requests of courts, government or law enforcement entities or where it is necessary to comply with applicable laws, court orders or rules, or government regulations.
Audits: Disclosures of personal information may also be needed for data privacy or security audits and/or to investigate or respond to a complaint or security threat.
In addition, IWLH may transfer certain personal information to external entities working with us or on our behalf for the purposes described in this Notice (e.g. in order to provide you with products or services you requested, or due to public or legal duty to do so). IWLH will not transfer the personal information you provide to any third parties for their own direct marketing use.
As such information may be transferred and disclosed to authorities, law enforcement, government, persons acting on your behalf, payment recipients, beneficiaries, intermediaries, other financial institutions, lenders and holders of security over any property relevant to IWLH, payment service providers, technology providers, support service providers, etc.
Please note that our services apply to children irrespective of age. We knowingly collect personally identifiable information from Children under the age of 18, under the strict supervision and consent of the child’s parent, guardian or legal custodian.
When you visit our website, IWLH uses cookie to ensure you will receive good experience from using the company’s website. Cookie is a small file that stores information and records it on to computer devices or communication tools when you access via web browser you choose while visiting the website.
Cookies may be placed on your computer or internet-enabled device whenever you visit IWLH online. This allows the site to remember your computer or device and serves a number of purposes.
Your selection will be saved in a cookie and is valid for a short period. If you wish to revoke your selection, you may do so by clearing your browser’s cookies. Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser’s settings (often found in your browser’s Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our web sites’ features.
Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers, but this is for the purpose of identifying the number of unique visitors to our web sites and geographic origin of visitor trends, and not to identify individual visitors. IWLH may also collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.
By navigating on our web sites and accepting cookies or entering your login details to access areas reserved for registered users, you agree that we can place these cookies on your computer or internet enabled device.
DATA SUBJECT RIGHTS
As a personal data owner, you have rights to request IWLH to process your personal data according to scope allowed by laws as below
Right to withdraw consent: you have rights to withdraw your consent for personal data processing as consents to IWLH anytime throughout the period your personal data stored at IWLH.
Right of access: you have rights to access your personal data and request IWLH for a copy of aforementioned personal data, including requesting the company to disclose the acquisition of your personal data you did not give your consent
Right to rectification: you have rights to request IWLH to correct incorrect data or add to incomplete data
Right to erasure: you have rights to request IWLH to erase your data by some reasons (depending on the circumstances and agreements in place). We may continue to process your information if another legitimate reason for doing so exists.
Right to restriction of processing: you have rights to request IWLH to suppress the use of your personal data by some reasons e.g the right to ask us not to process your personal data for marketing purposes.
Right to data portability: you have rights to transfer your personal data maintained by IWLH to other data controllers or yourself by some reasons
Right to object: you have rights to object your personal data processing by some reasons
If you have questions, requests, or complaints related to your privacy or would like to exercise data protection rights, please contact Privacy@lagoonhospitals.com