Privacy Policy
Integrated Health Care Limited (commonly known as “IHC” or “Integrated Health Care HMO”) reposes optimum value on its clients’ privacy. The Company`s Data Privacy Policy establishes the foundation for Integrated Health Care Limited’s collection, use and disclosure of personal data in accordance with relevant data protection laws. We are committed to international compliance with data protection laws. Personal Data includes any offline or online data that identifies a person, such as names, addresses, phone numbers, passport IDs, email addresses, passwords, digital footprints, photographs and health information collected while using or subscribing to our services (hereinafter collectively referred to as “Personal Data”). These data may also be obtained from third parties or gathered through the use of our website, WhatsApp, SMS, social media platforms and other digital channels.
With this policy, we ensure that data is collected, stored and handled fairly, openly and with regard for individual rights. For the purposes of this Privacy Policy, “we”, “our” and “us” refer to Integrated Health Care Limited.
We may amend our privacy policy from time to time, should there be change in government requirements, new technology, or other developments in data protection laws or privacy in general. You should visit the Integrated Health Care Limited website on a regular basis to view the most recent privacy policy.
The Purpose
This privacy statement refers to personal data processed in the course of Integrated Health Care Limited’s activity. It explains Integrated Health Care Limited’s approach to your data. This Privacy Policy comprises the internationally accepted data privacy principles without replacing the existing national laws. It supplements the national privacy laws.
The objective of this Policy is to further cultivate organization-wide privacy culture to protect the rights and privacy of individuals.
Personal Data Collection
The information we gather will be determined by our relationship with you. Such Information includes but not limited to:
- Identity Data: includes data such as first name, maiden name, last name, blood group, genotype, marital status, title, date of birth, next-of-kin data, health data and gender.
- Contact information for personal data, such as your home address, email address and phone number.
- Transaction Data: This includes information such as payment advice to you, as well as information on the capitation and fee-for-service claims paid by us.
• Marketing and Communication Data: This category includes information such as your preferences for getting marketing from us as well as your communication preferences.
How do we collect your Personal Data?
We acquire Personal Data from you directly in the following ways:
- enquiry, registration, claim forms, feedback forms and forums
- when you inquire about or purchase any of our health plans or services;
- when you complete a survey or vote in a poll on our website;
- through quotations and application forms;
- through cookies. (More information may be found in our cookies policy)
- during our phone calls with you, which may be recorded;
- when you offer your information to us online or offline;
- via SMS, WhatsApp, live chat, chatbots and profilers; and
- via site analytics tags
We also collect your Personal Data from a variety of sources, including:
- directly from an individual or employer who has a health insurance policy with us under which you are insured;
- directly from an employer who funds a health insurance policy that we administer and of which you are a beneficiary;
- from social media when fraud is suspected.
- Other third parties, such as: your family members if you are disabled or unable to submit information important to your insurance; • contractors, consultants and partners that utilize our services through their platforms and channels.
- medical professionals and hospitals
- third-party providers of information that we may utilize to influence risk selection, pricing, and underwriting choices
Information Collection
We gather data in order to render our services to you, or to process requests or applications made by you or on your behalf.
We gather data so we may get in contact with you and provide further information about our products and services as well provide needed support to you when required (this may be done via email subscriptions).
We also gather data so that we can reply to your inquiries or requests, as well as anticipate and handle problems with any services we provide to you.
Usage of Personal Data
We must have a legal justification to use and handle your Personal Data under relevant data protection laws. We have listed the major reasons why we process your Personal Data and the situations under which we will do so below:
- Processing is required for us to deliver your health insurance policy and services, such as evaluating your application and enrolling you in health insurance plan.
- We may employ both on-premise and cloud storage solutions, both inside and outside of Nigeria, to ensure efficiency and increased performance using cutting-edge technology.
- Where we have a legal or regulatory need to use such Personal Data, such as when our regulator, such as the National Health Insurance Authority (NHIA), requests that we keep certain records of our enrollees.
- Where we need to use your Personal Data to establish, exercise, or defend our legal rights, such as when we are faced with legal claims or want to pursue legal claims ourselves;
- Where we need to use your Personal Data for reasons of substantial public interest, such as investigating fraudulent claims and carrying out anti-money laundering and identification checks;
- When we need to interact with you in order to resolve complaints or other issues;
- When we have a special legal exemption to process sensitive Personal Data for insurance reasons. This exception applies when we need to handle your Personal Data as part of the insurance coverage, such as health information.
- Where you have given us permission to use your Personal Data upon obtaining your consent to handle sensitive Personal Data (such as health information) or to provide you with marketing materials (including information about other products and services). When you supply your Personal Data, this will be made apparent.
- Where you provide sensitive Personal Data about a third party, we request you confirm and provide proof that the third party has provided his or her consent for you to act on their behalf;
- Where we need to use your Sensitive Personal Data such as health data because it is necessary for your vital interests, especially in life or death situations.
Disclosing Personal Data
We may be required to disclose your personal information to third parties such as:
- National Health Insurance Authority or other Regulatory and Judicial Authorities
- Hospitals
- Service Providers, etc.
We may be obliged by law to disclose any information about you and we may make such disclosures to law enforcement agencies and other officials as necessary or appropriate under the circumstances.
Duration of Data Possession
We retain your Personal Data for as long as is reasonably required to perform the purposes outlined in this Privacy Policy and to comply with our legal and regulatory requirements. The duration of our retention of Personal Data is determined by the reasons for which we collect and use it, as well as by the period necessary to comply with relevant laws and to establish, exercise, or defend our legal rights.
Your Rights
You can request that we render services in view of your Personal Data. Instances of this can be via a request for a copy of your Personal Data, a request to fix errors, modify how we use your information, or even delete it. Such services requested for may be rendered or we may proffer reasons as to why we are unable to do so, which majorly is hinged on legal or regulatory restrictions.
In regard to our use of your Personal Data, you have the following rights.
The right to access your Personal Data:
You have the right to a copy of the Personal Data we keep on you, as well as specific facts about how we use it. Unless otherwise requested, your Personal Data will be disclosed to you in writing. To compensate the costs, we may charge you a modest fee.
The right to rectification:
We take reasonable measures to ensure that the Personal Data we have on file for you is correct and up to date. If you do not feel this is the case, please contact us using the information provided in your paperwork, and we will update or alter it.
The right to erasure:
You have the right to request that we destroy your Personal Data in certain instances, such as when the Personal Data we acquired is no longer required for the intended purpose or when you withdraw your consent. However, this must be assessed against other criteria, such as the type of Personal Data we retain about you and why we gathered it, as there may be some legal and regulatory guidelines proscribing us from complying with your request.
Right to processing restriction:
You have the right to request that we cease processing your Personal Data in certain situations, such as if you believe that the Personal Data we possess about you is erroneous or that we no longer need to use your Personal Data.
Right to data portability:
You have the right, in certain circumstances, to request that we transfer any Personal Data submitted to us to another third party of your choosing. Once transmitted, the third party will be liable for the protection of your Personal Data and all other ancilliary rights and liabilities will be so transferred.
The right to withdraw personal data:
You have the right to withdraw your Personal Data. Kindly bear in mind that upon the withdrawal of the data supplied to Integrated Health Care Limited, your continued access to insurance package may be hindered.
Our Responsibilities
We have well-maintained systems for keeping and managing your data and we pledge to use your data responsibly in accordance with the terms of this policy.
Furthermore, we restrict access to your personal data to only employees, agents, contractors and other third parties that require it in order for us to guarantee the delivery of quality our services to you. These individuals are bound by a duty of confidentiality and will only process your personal data on our instructions.
We have measures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach as required by law.
We acknowledge, however, that no database is totally secured or “hacker proof” and we only guarantee the confidentiality of your data to the degree that we take all reasonable precautions to safeguard.
We will only keep your personal information for as long as it is required to complete the reasons for which it was obtained, including any medical/health insurance, legal, accounting or reporting obligations.
Any query regarding data protection, including your requests and complaints, are promptly and timeously treated and all personal data are kept in accordance with this policy.
Security of Personal Data
We have put in place appropriate security measures to protect your personal data from being lost, misused, illegally accessed or disclosed in an unauthorised manner by a third party. Stringent measures have been implemented to protect your Personal Data.
Personal Data Protection Principles
When we process your Personal Data, we are guided by the following principles:
- We demonstrate strict compliance with the data protection principles which require Personal Data to be processed lawfully, fairly, in a transparent manner and with respect to the dignity of the human person.
- Such personal data so collected are only for specified, explicit and legitimate purposes and will not be further processed or used in a manner incompatible with those purposes.
Furthermore, data received are processed in a manner that ensures its security, using appropriate technical and organisational measures to protect against unauthorised or unlawful access and against accidental loss, destruction or damage