Introduction

At HSA, we are committed to protecting the personal and health information of our patients, employees, and partners. This Data Protection Policy outlines our approach to data protection and privacy in compliance with [Applicable Data Protection Laws].

Scope

This policy applies to all forms of data, whether electronic or paper-based, that HSA collects, stores, processes, and shares in the provision of our healthcare services.

Principles

HSA adheres to the following data protection principles:

• Lawfulness, Fairness, and Transparency: Data is processed lawfully, fairly, and in a transparent manner.
• Purpose Limitation: Data is collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes.
• Data Minimization: The collection of data is limited to what is necessary in relation to the purposes for which they are processed.
• Accuracy: Personal data is accurate and kept up to date.
• Storage Limitation: Personal data is kept in a form which permits identification of data subjects for no longer than is necessary.
• Integrity and Confidentiality: Data is processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage.

Data Subject Rights

Data subjects have the right to:

• Access their personal data.
• Request the correction or deletion of their personal data.
• Object to or restrict processing of their personal data.
• Data portability.
• Withdraw consent at any time, where relevant.
• Lodge a complaint with a supervisory authority.

Data Protection Measures

To uphold these principles and rights, HSA implements the following measures:

• Data Protection by Design and by Default: Incorporating data protection into the development and operation of all IT systems and business practices.
• Security Measures: Utilizing physical, technical, and administrative measures to ensure the security of personal data, including encryption, access controls, and information security policies.
• Data Protection Impact Assessments (DPIAs): Conducting assessments for processing activities that pose a high risk to data subjects’ rights and freedoms.
• Training and Awareness: Providing data protection training to all employees and relevant stakeholders.
• Data Breach Response: Establishing procedures for responding to data breaches, including notification to supervisory authorities and affected individuals where applicable.

Data Sharing and Transfers

Any sharing or transfer of personal data with third parties or international organizations will be conducted in compliance with applicable laws, ensuring that adequate safeguards are in place.

Responsibilities

• Data Protection Officer (DPO): HSA appoints a DPO responsible for overseeing data protection strategy and implementation.
• Employees: All employees are responsible for adhering to this policy and related procedures in their handling of personal data.

Review and Updates

This policy will be reviewed annually and updated as necessary to reflect changes in legal requirements, best practices, or organizational changes.

Contact Information

For any questions or concerns regarding data protection at HSA, please contact our Data Protection Officer at: