Please note that Clinical Network Systems (CNS) is the Data Processor of your personal data. The principles set out in this Privacy Notice apply to all instances in which CNS receives your personal data as a Data Processor for the purposes described in this notice. Those purposes are the processing of your data in order to facilitate the various functions of the PACENET application.
This privacy policy explains what information we collect through the PACENET application, when we collect it, how we use it, how it is secured, and your rights in relation to your personal data. We provide these services on behalf of your healthcare provider, typically your hospital’s Cardiology dept. In these cases, we are simply processing your personal information on their instruction. These parties are the Data Controllers in their own right and have their own privacy policies.
What Information We Collect
Personal Information
This means information that identifies you personally such as your name, address, contact details, appointment details, medical record details or data that can be linked with such information to identify you.
Automatically collected information
As part of routine clinical monitoring, Pacemaker information may be automatically uploaded from monitoring devices to the PACENET application and added to your record.
Information from other sources
We may collect information, including personal data, from other sources, such as the hospital’s PAS system. If we associate or combine information from these sources with the Personal Data that we collect through the PACENET application, we treat this information as Personal Data in accordance with this policy.
How do we use your personal information?
We DO NOT use your data for marketing purposes.
Any personal information that is submitted through the PACENET application or that is accessed by the PACENET application is required by the clinicians for providing the services by the healthcare provider.
Where we receive this information from your healthcare provider we rely on their legal basis for collecting and processing this information.
How do we store your personal information?
We will store your personal information on the Hospital’s secure servers which are located within the United States of America. We do not transfer your personal information outside the USA. All data is encrypted when its being transferred to and from the healthcare providers PC and the Hospital’s servers.
We take all steps reasonably necessary to ensure that your data is treated securely through strict procedures and security features to prevent unauthorized access to your personal information.
Protecting your data
We protect the personal data we hold from theft, accidental loss, corruption these protective measures include:
- Not collecting personal data that we don’t really need.
- Only allowing healthcare providers access to the personal data they need to carry out their duties.
- Encrypting personal data to render it useless to anyone who is not authorized to access it.
- Making sure that healthcare providers are trained on how to use the PACENET application.
How long do we store your personal information?
We will retain your personal information for as long as your healthcare provider needs it in line with the data retention policies of your hospital’s records management code of practice.
What rights do you have?
By law, you have a number of rights (subject to certain conditions) when it comes to your information. Further information and advice about your rights can be obtained from the Information Commissioners Office (ICO). You can exercise any of these rights by contacting us using our details below.
You can submit a complaint to Clinical Network Systems at any time by contacting;
Roy Margolis,
Chief Technical Officer
roy.margolis@clinicalnetworksystems.com
You have the right to complain to our supervisory authority. We are based in the UK and our Supervisory Authority is the UK Information Commissioner’s Office, and more information can be found here: https://ico.org.uk/concerns
or you can write to the ICO by using this address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Or you can file a complaint with the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) using this address:
200 Independence Avenue, S.W.,
Washington D.C. 20201
Or calling 1-877-696-6775, or visiting www.hhs.gov/ocr/privacy/hipaa/complaints/.
Changes to this Privacy Policy
We update our privacy policy from time to time and any changes we may make to our privacy policy in the future will be posted online.
This Policy was last updated on February 1, 2022.