C & S West Medical Services Ltd.
Privacy Notice

C & S West Medical Services Ltd (CSW) uses information about you, or that can identify you, and we are committed to using your personal information in a lawful and fair manner, and in compliance with the Bermuda’s Personal Information Protection Act 2016 (“PIPA”). This Privacy Notice is provided to you in compliance with our privacy notice requirements under PIPA.

 

What personal information we collect from you

We collect, use, and disclose personal information and sensitive personal information (as defined in PIPA) about you only for the following purposes for which it is collected. We do not sell or otherwise commercially exploit your personal information, nor do we use it for any third-party marketing purposes.

 

The types of information, including personal information, that we may collect and use

First, we collect and may use whatever personal information that you or your healthcare professional provide to us in connection with the uses and purposes described herein. “Personal Information” that we may collect and use is comprised of information that can be used to identify you, or that may make you identifiable, and may include:

  • Full name, date of birth and residential address;
  • Medical Record Number (MRN) and hospital financial number (FIN);
  • Billing and health insurance information; and
  • Relevant supporting documentation of consent or authorization.

 

We may also collect, store and use the following “special categories” of more sensitive personal information[1] including:

  • Ethnicity, place of origin, race and colour;
  • Sex, sexual orientation and sexual life;
  • Marital and family status/history;
  • Present and past physical and mental health status/history;
  • Hospital appointment/visit details; and
  • Present and past symptoms, medications, allergies and drug sensitivity.

 

  1. How to contact us about our handling of personal information

For any inquiries or concerns regarding our handling and use of your personal information, please contact our Privacy Officer.

 

Privacy Officer: Denise Bremar, VP – Practice Manager

Contact Information: 29 Mangrove Bay Road, Sandys MA01, Bermuda

Tel:(441) 234-3674

Email: dbremar@cswest.bm

 

  1. The purposes for which personal information is or might be used

We may use the personal information that we collect for the following purposes:

  • For public health and safety issues;
  • For research;
  • As required by law;
  • At the request of the doctor or healthcare professional treating you;
  • To respond to government requests;
  • To respond to lawsuits and legal actions;
  • Treatment purposes;
  • CSW’s healthcare operations; and
  • Billing and payment processing.

 

  1. The identity and types of individuals or organizations to whom personal information might be disclosed

CSW will, or may, disclose your personal information to the following individuals and organizations. The list below is non-exhaustive and will be updated periodically as and when the purposes, use and individuals to whom personal information will be provided change:

  • Your physician’s office;
  • Any medical service provider or organization requested by your physician’s office;
  • Laboratory Corporation of America (LabCorp); and
  • Bermuda Government Epidemiology and Surveillance Unit of the Chief Medical Officer.

 

The types of individuals or organizations that we may provide your personal information are as follows:

  • Laboratories for confirmation and additional testing;
  • Individuals, public authorities and public officers responsible for the performance of public tasks and responding to public health emergencies;
  • Healthcare organizations and professionals involved in your care;
  • Medical insurance providers; and
  • Certification and accreditation bodies.

 

  1. Means we use to allow you to control our use of your personal information in accordance with PIPA

You have a right to request and CSW is required to provide:

  • Personal information about yourself which is in the custody or under the control of CSW;
  • The purposes for which your personal information has been and is being used by CSW; and
  • The names of the persons or types of persons to whom and circumstances in which your personal information has been and is being disclosed.

 

Under PIPA, CSW may lawfully refuse a request for access to personal information if such access would be likely to prejudice the physical or mental health of the requester, and the personal information is:

  • Of a medical or psychiatric nature relating to the requester, or
  • Kept for the purposes of, or obtained in the course of, the carrying out of social work in relation to the requester.

To obtain access to, or make a request for a correction to, your personal information, or to exercise any other rights that you have under PIPA, please submit a written request to the Privacy Officer, which must include sufficient information to enable us, with reasonable effort, to identify the personal information that is relevant to your request.  Your request must also include all necessary contact information for us to respond to your request.

You will be contacted by one of our administrators promptly to confirm receipt of your request.

Please note the following information associated with any request that we receive from you:

  • We require your accurate and complete name, contact information;
  • We will confirm our receipt of your enquiry or instructions after we have received same
  • We will take a reasonable amount of time to process your enquiry or instructions and initially respond to your request, but usually no more than 45 days (depending upon the nature and complexity of your request).

CSW reserves all of its rights and protections afforded to it under PIPA. CSW reserves the right to update and revise this privacy notice at any time, as we may determine to be prudent or necessary to reflect changes in our privacy practices or legal requirements.

 

 

[1] The Privacy Commissioner has shared that “sensitive personal information” is any personal information relating to an individual’s: place of origin; race; colour; national or ethnic origin; sex; sexual orientation; sexual life; marital status; physical or mental disability; physical or mental health; family status; religious beliefs; political opinions; trade union membership; biometric information; or genetic information.