Introduction
This privacy notice outlines the practices employed by The University Hospital of the West Indies Private Wing (hereinafter referred to as Tony Thwaites Wing or TTW). The Tony Thwaites Wing is responsible for handling and safeguarding the information provided by individuals interacting with the healthcare facility, either through its website or on-site. Adhering to privacy regulations like the Jamaica Data Protection Act, 2020 (JDPA), TTW is dedicated to ensuring the protection of your privacy. Any information requested to identify you will be used strictly in accordance with this privacy notice. The healthcare facility retains the right to periodically modify this notice by updating the corresponding web page which can be located on our website at www.ttwing.com, and it is advisable to check for periodic updates.
This privacy notice aims to help you understand our personal data collection system, its usage, processing, storage, sharing, and the security measures implemented to safeguard your personal data. This notice addresses:
- The nature of the personal data collected from you, the data subject.
- The methods employed in collecting, using, sharing, storing, and processing personal data.
- The security protocols implemented to ensure the protection of your data.
- Your options and rights concerning the use of your data.
- Procedures for contacting us to address issues such as correcting inaccuracies in your data or requesting the removal of your personal information.
We encourage you to carefully review this privacy notice to gain a comprehensive understanding of how your data is processed, collected, shared, and protected and the rights associated with it.
Who We Are
Tony Thwaites Wing is a non-profit healthcare facility. Our mission is to provide world-class health care to individuals in the region and internationally without the expenses and anxiety of having to travel far away from home and, to do so, we collect and use personal data that you provide.
For this notice, we act as the “data controller”. We take on this role as we determine how your data is used and processed.
We have appointed a Data Protection Officer (DPO) to assist with questions, requests, and complaints regarding this privacy notice and the collection and processing of your data. For details on how to contact us, see the Contact Information section at the end of this notice.
Data We Collect
We have access to any data that you voluntarily provide via email, telephone, forms, chat functions, patient registration, newsletter sign-up, contests, and surveys.
Through these means, we collect the following types of data:
- Full name
- Contact information (Email address, Phone number)
- Health Status
- Address
- Date of birth
- Information about any complaints, inquiries, and communication you make with us.
- Details on services received from us.
- Location
- Biometric Information
- Sex life
- Gender
- Occupation
- Qualification
- ID
- Familial affiliation
- Insurance Information
This is a non-exhaustive list which is reflective of the varied nature of the Personal Data processed as part of us providing you with certain services.
Note, however, where you do not provide us with the personal data requested by us, we may be delayed or unable to provide services to you.
How We Use Your Data
We require this information to understand your needs and provide a better service. Your data may be used for the following purposes:
- Make diagnoses and provide the best health care possible.
- Assist in our hiring and decision-making processes.
- Customization of content and user experience.
- Improve our products and services.
- Internal record keeping.
- Promotional emails regarding new products, special offers, or other information that you have consented to be sent in the event such information is made available.
- Account set up and administration.
- Conducting polls, surveys, and contests.
- Internal research and development.
- Legal obligations.
- Internal audits.
- Fulfillment of obligations outlined in any agreements with users.
- Gather feedback and opinions on the services we provide.
- Notification of changes to our services.
- Respond to your requests and comments.
- Process your transactions.
Legal Basis of Processing
We process your personal data to perform our contract entered into with you as a data subject or for the taking of steps at your request to enter into a contract.
We process personal data for our legitimate interests, granted that those interests do not override any of your interests, rights, and freedoms. This legitimate interest includes processing for marketing, research, and business development purposes.
We also process personal data for other purposes with your consent, but you have the right to withdraw consent to processing for specific purposes, as outlined below. We may also process certain personal data because of a legal obligation with which we must comply, other than an obligation imposed by contract.
Specific Data Use
To ensure that you, our patient, receive optimal healthcare, you need to furnish contact details (such as name and phone number), information about your mental and physical health conditions, financial details, and potentially other sensitive personal data to facilitate the healthcare process. This information will be utilized for diagnosis, treatment, and billing. There may also be situations where we need to reach out to you subsequently.
When reaching out to us through our website, you will be prompted to supply your name and contact details (email address and phone number), along with the message you wish to convey. Subsequently, you can send a letter to us. This information is used in cases where we need to respond to you or if further clarification is required. Additionally, the data may be used to communicate with you for suggestions regarding relevant products and services and to enhance your overall user experience.
Personal data may be used without knowledge or consent in situations when legally required or permitted or when personal data has been anonymized or pseudonymized, so it is no longer associated with you. This means we have removed personal identifying information, so the data we are left with cannot be tied back to you as an individual.
How We Share Your Data
Personal data may be shared with regulators in compliance with legal regulations.
Personal data may also be shared with third parties when it is necessary to provide services to patients and consultants and for other legitimate interests. Third parties include service providers, professional advisors, and other members of Tony Thwaites Wing’s network.
Third parties that may access personal data are fulfilling the following services: web hosting, order/purchase fulfilment, IT and cloud services, and laboratory services. These parties do not retain, share, or use personal data beyond the defined purpose of fulfilling the service.
We share only aggregated demographic data with our partners and advertisers. This data is not linked to the identity of any individual user.
Where We Process Your Data
Under certain circumstances, the personal data that we collect may be transferred to other countries for various purposes outlined below.
- Invoicing
- Insurance purposes
- Order fulfillment
- Patient transfer
- To obtain quotes
There may be circumstances in which the personal data would be transferred to a territory outside of Jamaica and such territory may not provide for an adequate level of data protection as granted in Jamaica. We have implemented security measures and controls to ensure data remains appropriately protected in these jurisdictions.
How Long We Store Your Data
We will only retain personal data for the duration necessary to fulfil the purposes for which it was collected. Personal data may also be kept for more extended periods if it is solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes. When defining the appropriate retention length, we adhere to relevant legal requirements, such as the Medical Act.
How We Protect Your Data
Securing your data, both online and offline, is a priority for us. We have implemented appropriate safeguards to prevent personal data from being lost, misused, accessed, altered, or disclosed by unauthorized parties.
Secure web access can be verified by the lock icon in our internet browser address bar and by the use of “https” at the beginning of the web address, where the “s” indicates a secure connection.
Employees and third parties are provided only with personal data on a need-to-know basis and only the minimum amount they require to complete their specific job. All employees are also subject to confidentiality agreements and undergo annual training on the proper handling of sensitive data.
Procedures have been developed and tested to handle a potential data breach. These procedures are designed to ensure affected individuals and regulators are notified of the violation, and damages can be minimized.
Use of Cookies
A cookie is a small file that asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes, and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyze data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes, and then the data is removed from the system. Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not.
A cookie in no way gives us access to your computer or any information about you other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Your Rights Regarding Your Data
We aim to maintain data that is accurate and up to date. If your data changes (e.g., moving addresses), please notify us immediately.
In certain instances, you have the legal right to the following:
- Request all data we have collected about you, if any.
- Request correction to the personal data we have collected about you.
- Right to consent to the process for direct marketing.
- Object to the processing of personal data.
- Right to prevent the processing of your data.
- Opt out of contact with us at any time.
- Express any concern about any data we have collected about you.
- Right to consent and withdraw consent to direct marketing.
If you believe that any knowledge, we are holding on to you is incorrect or incomplete, email us at dpo@ttwing.com as soon as possible. We will promptly correct any data found to be incorrect.
To exercise these rights, please get in touch with us via the email, mail, or phone information provided below in the “Contact Information” section.
External Links
On our website, you may encounter links to other websites. Be aware that we are not responsible for the content or privacy practices of these other sites. We encourage all users to read the privacy notices of any other sites that collect your data.
Contact Information
For any questions, concerns, or requests to exercise your rights outlined in this privacy notice, please get in touch with us via our:
Mailing Address
U.H.W.I Private Wing Ltd.
P.O Box 133, Mona,
Kingston 7
Telephone Numbers
876-977-0309
876-977-2607
876-977-0317
Fax
876-977-0094
E-mails
Admissions Office: admissions@ttwing.com
Customer Service: patientaffairs@ttwing.com
Data Protection Officer (DPO) dpo@ttwing.com
Changes to This Privacy Notice
This privacy notice was last updated on August 30, 2024.
Any changes to this privacy notice can be found on our website. We may also make changes as required to comply with changes in applicable law or regulatory requirements. Where it is practicable, we will notify you by email of any significant changes. However, we encourage you to review this privacy notice periodically to be informed of how we use your personal data.
Terms of Use
From time to time, we will update these terms of use.
Welcome to the Tony Thwaites Wing website. In the case where you continue to use our website, you agree to comply with and be bound by the following terms and conditions of use, which, together with our privacy policy, govern the Tony Thwaites Wing relationship with you concerning this website.
The term ‘COMPANY’ or ‘us’ or ‘we’ refers to the owner of the website whose registered office is P.O Box 133, Mona, Kingston 7. The term ‘you’ refers to the user or viewer of our website. The use of this website is subject to the following terms of use:
- The content of the pages of this website is for your general information and use only. It is subject to change without notice.
- Neither we nor any third parties provide any warranty or guarantee as to the accuracy, timeliness, performance, completeness, or suitability of the information and materials found or offered on this website for any particular purpose. You acknowledge that such data and materials may contain inaccuracies or errors, and we expressly exclude our liability for any such inaccuracies or errors to the fullest extent permitted by law.
- Your use of any information or materials on this website is entirely at your own risk, for which we shall not be liable. It shall be your responsibility to ensure that any products, services, or information available through this website meet your specific requirements.
- This website contains material that is owned by or licensed to us. This material includes, but is not limited to, the design, layout, look, appearance, and graphics. Reproduction is prohibited other than in accordance with the copyright notice, which forms part of these terms and conditions.
- All trademarks reproduced on this website that are not the property of, or licensed to, the operator is acknowledged on the website.
- Unauthorized use of this website may give rise to a claim for damages and be a criminal offence.
- From time to time, this website may also include links to other websites. These links are provided for your convenience to provide further information. They do not signify that we endorse the website(s). We have no responsibility for the content of the linked website(s).
- You may create a link to this website from another website or document without the company’s prior written consent.
- Your use of this website and any dispute arising out of such use of the website is subject to the laws of Jamaica.