PRIVACY POLICY FOR USING THE ELECTRONIC VACCINATION DATA SYSTEM (EVDS)
Medscheme Holdings (Proprietary) Limited (“Medscheme”) is an accredited medical scheme administrator and managed health care organisation in terms of the Medical Schemes Act 131 of 1998 in terms of which it is contracted to your medical scheme to bring you administration and managed health care services.
Medscheme is a subsidiary of the AfroCentric Group of companies, and as part of the AfroCentric Group, it has joined the fight against COVID-19 pandemic in support of the efforts made by your medical scheme, the government of the Republic of South Africa in particular the National Department of Health (“NDoH”) to bring you, as the member of our client medical scheme, systems that will enable you to register for your vaccination.
“We, us, our” refers to all the parties that are mentioned above including third parties that are contracted to your medical scheme to bring you information and services related to the roll-out of the COVID-19 Vaccination by the NDoH and the government of South Africa.
The NDoH has developed an EVDS to support the COVID-19 Vaccination roll out in South Africa. The EVDS will be used to capture COVID-19 vaccination events digitally and provide data to NDOH data analytics platform to monitor and report on.
In order to do this, we require you to disclose your Personal Information, as defined below, from the cellular telephone/s and digital applications that you use. This will assist us with coordinating your registration on the EVDS efficiently. It will also ensure that you receive the appropriate vaccination at the appropriate time and site.
By providing us with your personal information, you –
· agree to this Policy and authorise us to process such information for the permitted purpose;
· agree that we may disclose your personal information to NDoH, for the roll-out of the COVID-19 Vaccination purposes, in accordance with applicable law and subject to applicable professional and regulatory requirements regarding confidentiality;
· authorise Medscheme, its affiliates, directors, employees, consultants, service providers and other third parties to process your personal information for the permitted purpose stated in this Policy.
You acknowledge that you are giving your consent voluntarily without being forced, influenced, pressured or harassed to do so.
You are entitled to withhold, withdraw, change or revoke your consent relating to any aspect of the processing of your personal information for a permitted purpose. However, you acknowledge that if you do so, we may not be able to provide you with the registration on EVDS and the stated permitted purpose.
Personal Information refers to all information that relates to an identified or identifiable person, including but not limited to your full name, identity number, medical aid and membership number, contact details, physical and postal address, gender, employment details, etc.
Process or processing means any operation with personal data, irrespective of the means applied and the procedure, and in particular the collection, storage, use, revision, disclosure, archiving, or destruction of data.
Medscheme has made it easier for you to access the EVDS on your medical scheme website or via the WhatsApp facility to facilitate and expedite your registration on the EVDS.
Where you do not have access to any digital platforms, and with your authorisation, Medscheme has the capability to register you and your dependants on the EVDS via the call centre. This can be done via your medical scheme’s call centre where you will need to phone in and request the call centre agent to assist you personally. The calls will be recorded and you are entitled to request a copy of the call in accordance with our Promotion of Access to Information Manual.
PURPOSES OF PROCESSING AND LEGAL BASES FOR PROCESSING
When you choose to use the EVDS via the platforms provided by Medscheme and your medical scheme, we shall process your personal information in the following manner (“permitted purpose”):
· provide your personal information that are required by the NDoH to identify you;
· combine all the information that we have about you to compile a profile for you in order for us to personalise and tailor EVDS to your membership;
· record your call during the call centre interaction with our agents who will be assisting you with your registration on the EVDS;
· collect your personal information you provide on the EVDS to link you to your membership with your medical scheme;
· collect or share your personal information, whichever is applicable, with the NDoH for reporting purposes;
· access your location so that we can link you to the nearest vaccination site;
· create a personal information file about you such as records of your communications and interactions with us; and,
· store your personal information for our records and in relation to your membership with your medical scheme.
We will not use your personal information for any purpose other than that set out in this Policy and will endeavour to protect your personal information that is in our possession from unauthorised alteration, loss, disclosure or access.
When you use or access the EVDS via the digital platforms or call centre, you are granting Medscheme and your medical scheme voluntary consent to process your personal information for the permitted purpose with the NDoH, which is responsible for the vaccination procurement and roll-out strategy for the Republic of South Africa.
You further confirm that your vaccination information may be stored by Medscheme and your medical scheme, and thereafter shared with the NDoH for reporting purposes as and when required by the NDoH.
PROTECTION OF PERSONAL INFORMATION
Medscheme and your medical scheme undertake to continue maintaining the privacy, safety and integrity of your personal information in so far as it is held in our storage systems, as it has always done. We will not sell, rent or provide your personal information to any unauthorised entities or other third parties for their independent use, without your express consent.
We implement reasonable technical and organisational security measures to protect your personal information that is in our possession against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or unauthorised access.
That being said, as the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your personal information that is in our possession, we cannot guarantee the security of any information transmitted to us using the internet on the EVDS. Any such transmission is at your own risk and you are responsible for ensuring that any information that you send to the EVDS is sent securely.
Medscheme and your medical scheme will not be responsible for unauthorised access to your personal information on the EVDS and, to the extent permitted in terms of the applicable law, any liability to you which may otherwise have been attributable to Medscheme as a result of or in connection with such unauthorised access, is hereby excluded.
INTERNATIONAL TRANSFER OF PERSONAL INFORMATION
We may transfer your Personal Data to recipients outside of the Republic of South Africa.
Personal information may be transferred to a third party outside of the Republic of South Africa provided that the third party is subject to a law, binding corporate rules or a binding agreement that seeks to protect the personal information in line with this Policy and the transfer is necessary in order to provide the services that are required by you.
INFORMATION ACCURACY
The personal information provided to Medscheme and your medical scheme should be accurate, complete and up-to-date. Should personal information change, the onus is on the provider of such information to notify Medscheme of the change and provide Medscheme with the accurate information.
INFORMATION MINIMISATION
Medscheme and your medical scheme will restrict the processing of personal information to information which is sufficient for the fulfilment of the primary purpose and applicable legitimate purpose for which it was collected, subject to the provisions of this Policy.
INFORMATION RETENTION
Medscheme shall only retain and store personal information for the period for which the information are required to serve their primary purpose or a legitimate interest or for the period required to comply with an applicable legal requirement, whichever is longer.
YOUR LEGAL RIGHTS
You have rights under the South African and other laws to access your personal information and to ask us to rectify, erase and restrict use of, your personal information. You also have the right to object to your personal information being used, to ask for the transfer of personal information you have made available to us and to withdraw consent to the use of your personal information.
COOKIES AND SIMILAR TECHNOLOGIES
Cookies are a small file that are placed on your device when you visit a website or application. In this Policy, a reference to a "Cookie" includes analogous technologies such as web beacons and clear graphic interchange format files.
We may Process your personal information by our use of Cookies and similar technologies.
When you visit our Website or App we may place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We may process your personal information through Cookies and similar technologies.
HYPERLINKS TO OTHER WEBSITES
Third party operators of websites, which may be accessed via hyperlinks from our Website or App, may gather and store personal information as soon as you access their websites. We do not accept any liability for those Operators in the event that your personal information is collected, used, disclosed or shared by them. We encourage you to read their privacy policies separately.
HOW DO YOU CONTACT US?
If you have questions about this Privacy Policy, or wish to amend or update any of your personal information you may contact your Scheme