This notice was last updated on December 10, 2018
We may change this notice from time to time to stay aligned and current with the changes in the general data protection regulation (GDPR).
Data Protection Privacy Notice - Introduction:
This privacy notice lets you know what happens to any personal data that you give to us, or any that we may collect from or about you.
This privacy notice applies to personal information processed by or on behalf of HealthRCM.
This notice identifies:
• Who we are and how we use your information;
• Our Data Protection Officer;
• What kinds of personal information about you do we process;
• What are the legal grounds for our processing of your personal information (including when we share it with others);
• What should you do if your personal information changes;
• For how long your personal information is retained by us;
• What are your rights under data protection laws.
The General Data Protection Regulation (GDPR) became law on 24th May 2016. This is a single EU- wide regulation on the protection of confidential and sensitive information. It entered into force on the 25th May 2018, repealing the Data Protection Act (1998).
This notice describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
How do we use your information?
HealthRCM will be what is known as the ‘Controller’ of the personal data provided to us.
We collect basic personal data about you which does not include any special types of information or location-based information. This does however include name, address, contact details such as email and mobile number, etc.
We will also collect sensitive confidential data known as “special category personal data” in the form of health information, religious belief (if required in a healthcare setting) ethnicity, and sex during the services we provide and or linked to your healthcare through health providers or third parties.
Why do we need your information?
Medical coding is the transformation of healthcare diagnosis, procedures, medical services, and equipment into universal medical alphanumeric codes. The diagnosis and procedure codes are taken from medical record documentation, such as transcription of provider's notes, laboratory and radiology results, etc. Medical coding professionals help ensure the codes are applied correctly during the medical billing process, which includes abstracting the information from documentation, assigning the appropriate codes, and creating a claim to be paid by insurance carriers.
How do we lawfully use your data?
We receive records/documents with your personal, sensitive and confidential data in order to provide services for compliant healthcare services as a coding company, under the General Data Protection Regulation we will be lawfully using your information in accordance with: -
Article 6(e)- processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller;
Article 9(h)- processing is necessary for the purposes of preventive or occupational medicine for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems.
This privacy notice applies to the personal data also received regarding caretakers and family members.
How do we maintain the confidentiality of your records?
We are committed to protecting your privacy and will only use information collected lawfully in accordance with The General Data Protection Regulation.
We will only ever use or pass on information about you if others involved in your care have a genuine need for it. We will not disclose your information to any third party without your permission unless there are exceptional circumstances, where the law requires information to be passed on.
Our policy is to respect the privacy of our clients to maintain compliance with the GDPR. Our policy is to ensure all personal data related to our clients will be protected.
All employees and sub-contractors are asked to sign a confidentiality agreement. If a subcontractor acts as a Data Processor, an appropriate contract will be established for the processing of your information.
In certain circumstances, you may have the right to withdraw your consent to the processing of data. Please contact the Data Protection Officer in writing, if you wish to withdraw your consent.
If some circumstances we may need to store your data after your consent has been withdrawn to comply with a legislative requirement.
Where do we store your information electronically?
All the personal data we process is processed by our staff for the purposes of IT hosting and maintenance. This information may be located on servers within the European Union.
No third parties have access to your personal data, unless the law allows them to do so and appropriate safeguards have been put in place. We have a data protection regime in place to oversee the effective and secure processing of your personal and/or special category (sensitive, confidential) data.
Who are our partner organizations?
We may also have to share your information, subject to strict agreements on how it will be used,
with the following organizations:
• Fire and Rescue Services,
• Police & Judicial Services,
• Other ‘Data Processors,’ which you will be informed of.
You will be informed who your data will be shared with and in some cases asked for consent for this to happen, when this is required.
We may also use external companies to process personal information, such as for archiving purposes. These companies are bound by contractual agreements to ensure information is kept confidential and secure. All employees and sub-contractors engaged are asked to sign a confidentiality agreement. If a sub-contractor acts as a data processor an appropriate contract will be established for the processing of your information.
How long will we store your information?
We are required under law to keep your information and data for the full retention periods. The company Data Retention Schedule can be discussed with the Data Privacy Officer (DPO).
More information on records can be found online at:
How can you access, amend, or move the personal data that you have given to us?
Even if we already hold your personal data, you still have various rights in relation to it. To learn more, please contact us. We will seek to deal with your request without undue delay, in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues you raise.
Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within thirty (30) days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.
Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, a research project), you may withdraw your consent at any time.
Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to "erase" your personal data. We will respond to your request within thirty (30) days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will delete your data, but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. In doing so, we will minimize the chances of you being contacted in the future. If you would prefer us not to do this, you are free to say so.
Right of data portability: If you wish, you have the right to transfer your data from us to another data controller, we will assist.
Access to your personal information
Data Subject Access Requests: You have a right under the Data Protection legislation to request access to view or to obtain copies of what information there is about you and to have it amended should it be inaccurate.
• Your request should be made to HealthRCM
• There is no charge to have a copy of the information held about you
• We are required to respond to you within one month
• You will need to give adequate information (for example, full name, address, date of birth, and details of your request) to help verify and locate your records.
Objections / Complaints
Should you have any concerns about how your information is managed at HealthRCM , please contact the DPO. If you are still unhappy following a review, you have a right to lodge a complaint with a Supervisory Authority: You have a right to complain to the Estonian Supervisory Authority as listed below.
Nõuandetelefon +372 5620
Üldtelefon +372 627 4135
If consent to your data to be extracted and used for the purposes described in this privacy notice, then you do not need to do anything.
If you would like to know more about your rights in respect of the personal data, we hold about you, please contact the DPO as below.
Data Protection Officer:
The DPO is Maiu Reismann. Any queries in regard to Data Protection issues should be addressed to:
Tornimäe 5, 10145 Tallinn
M: +372 56 354 287