List of examples:
This Privacy Policy is under development.
Privacy Policy of openIMIS
Last modified on April 24, 2020
PLEASE READ THIS PRIVACY STATEMENT CAREFULLY BEFORE USE OF OPENIMIS SERVICES.
The protection of your privacy and your personal data (as defined in Article 4(1) of the Data Protection Basic Regulation (EU) 2016/679 ("DSGVO") is very important to openIMIS ("us", "our" or "we"). It is extremely important for us that openIMIS users ("users") feel secure when using our services.
This Privacy Policy forms the basis on which personal data are collected from you. Please read this Privacy Policy carefully to understand the categories of personal information we collect from you, the circumstances in which we may disclose it to third parties and your rights regarding the personal information you provide to us.
When you use our mobile applications "openIMIS Policies" or "openIMIS Claims" (the "App") or openIMIS web-based application ("Web-embed") (together with the App and Web-embed referred to as the "Services"), you might be asked to confirm that you have read and understood the information described in this Privacy Policy.
1. Who we are
This Privacy Policy applies to the processing of personal data by the openIMIS software as well as the openIMIS initiative. The copyright for the openIMIS software is held by the Swiss Agency for Development and Cooperation, and is licensed as open-source software using the AGPL3 licence. Details on the license can be found in: openIMIS Software License . The openIMIS initiative, to promote and streamline the further development of the software, is currently managed by Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ).
Questions, comments and enquiries regarding this data protection and privacy declaration are welcome and should be directed to openIMIS Service Desk (https://openimis.atlassian.net/servicedesk).
2. General overview of our data processing activities in connection with the Services
openIMIS will collect and process the following data from you:
Information that you provide us with. You are asked to provide us with information when you:
Create an account on the "Web-embed";
Create or update a family on the "Web-embed" or on the "app"
Create or update a family member on the "Web-embed" or on the "app"
Create or update a policy on the "Web-embed" or on the "app"
Create or update a contribution/payment on the "Web-embed" or on the "app"
Create or update a claim on the "Web-embed" or on the "app"
3. Specific processing activities and the nature and purpose of data use
3.1 If you create an account on the "Web-embed"
-categories of data: Language, names, E-mail address and password, user ID, main health facility (optional), location of works, phone (optional), Permanent Address Details(optional), date of birth (optional) and time and date of registration.
-Purposes of processing: grant access to the "app" and "Web-embed", generate report for the enrollment officer and the claim administrator and perform audits
-Legal basis: legitimate interest (Article 6 (1) (f) GDPR): processing is necessary for the purposes of legitimate interests.
-Storage period: as long as the user is registered in the "Web-embed"
3.2 If you create or update a family or a family member on the "Web-embed" or on the "app"
-categories of data for a family: id, head of the family, Region, District, Municipality, Village, poverty status(optional), confirmation type (optional), family group type (optional)and time and date of registration.
-categories of data for family members :photos, id, insurance number, Names, date of birth, gender, Marital status (optional), Beneficiary card (optional), Region(optional), District(optional), Municipality(optional), Village(optional), Current Address(optional), Profession(optional), Education(optional), Phone(optional), Email(optional), Identification Type(optional), Identification Number(optional), first point of care(optional) and time and date of registration.
-Purposes of processing: allow validation of the claim to be generated by the health facilities on behalf of the family and its members
-Legal basis: legitimate interest (Article 6 (1) (b) GDPR): processing is necessary for the performance of a contract.
-Storage period: as long as the user is registered in the "Web-embed"
3.3 If you create or update a policy, contribution/payment on the "Web-embed" or on the "app"
-categories of data for policy: id, enrollment date, product, start date, expiry date, enrollment officer, policy value and time and date of registration.
-categories of data for contributions/payment: id, payer (optional), contribution category (optional), amount, Receipt No., Payment Date, Payment Type and time and date of registration.
-Purposes of processing: activate a contract with the family
-Legal basis: legitimate interest (Article 6 (1) (b) GDPR): processing is necessary for the performance of a contract.
-Storage period: as long as the user is registered in the "Web-embed"
3.4 If you create or update claim on the "Web-embed" or on the "app"
-categories of data: health facility, claim administrator, diagnoses, insuree number, claim date, care dates, visit type, Claim ID, claim number, services and items claimed, guarantee number(optional).
-Purposes of processing: enabling the calculation of the amount to be reimbursed to the health facility base based on the service provided (claim valuation and capitation on claim number/amounts). also for auditing
-Legal basis: legitimate interest (Article 6 (1) (b) GDPR): processing is necessary for the performance of a contract.
-Storage period: as long as the "Web-embed" is active
4. Where are stored your personal information
The personal data collected from you will be stored the "Web-embed" server.
If collected via the app, they will be:
stored on the IMIS folder in your root directory for the photos and connection tokens
in the application database located in the application folder for the other information (not accessible for non-root user)
Those data are erased after synchronization with the service of generation of an export archive (encrypted via password, stored in the IMIS folder).
Sensitive information exchanged between your browser and our website is transmitted in encrypted form using Transport Layer Security ("TLS"). When transmitting sensitive information.
5. Recipient of your personal data
6.1 In order to provide and maintain the services, the data recipient are the insurance scheme owner. Please check their privacy statement to know if your information is shared with third parties. The demo data of https://demo.openimis.org are not shared and are erased every week.
6. How long we store your personal data
openIMSI will retain the above information for as long as is necessary to provide the Services to you or to resolve specific problems that may arise or as otherwise required by law or regulatory authorities. Certain retention periods for the processing activities concerned are set out above under 3.
If your personal information is used for two different purposes, openIMIS will retain this information until the purpose with the longer retention period no longer exists, but will not use it for the purpose with the shorter retention period once that period has expired.
openIMIS limits access to your personal information to those persons who need it for the relevant purpose(s).
7. Your rights
According to the basic data protection regulation (EU) 2016/679, you have various rights with regard to your personal data.
These rights can be exercised by sending a service desk request to https://openimis.atlassian.net/servicedesk
Verification: To verify your request, we will take reasonable steps, such as asking you to send us confirmation from the email address associated with your account so that we can verify that you are the owner of that email account. If no email address is associated with your account, we may ask you for a copy of your ID.
-Right to withdraw consent: You have the right to withdraw your consent at any time by notifying us by email to dpo@ada.com. A revocation of your consent does not affect the legality of the processing based on your consent up to the time of revocation.
-Right of objection: You have a right of objection under the conditions of Article 21 DSGVO. You will find more detailed information on this below:
Right of objection in case of processing based on legitimate interests: As a data subject, you have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data relating to you carried out pursuant to Article 6 (1) (e) or (f) FADP, including profiling based on these provisions. In the event of an objection for reasons arising from your particular situation, we shall no longer process the personal data concerned unless we can demonstrate compelling legitimate reasons for processing which outweigh your interests, rights and freedoms, or unless the processing is for the purpose of asserting, exercising or defending legal claims.
Right to object to processing for statistical purposes: If we process your personal data for statistical purposes pursuant to Art. 9 (2)(j) GDPR, § 27 (1) BDSG, you have the right to object to such processing for reasons arising from your particular situation. In the event of such objection, we will no longer process the personal data concerned for this purpose, unless the processing is necessary for the performance of a task carried out in the public interest or if the discontinuation of the processing is likely to make the achievement of the statistical purposes impossible or seriously prejudice them and the continuation of the processing is necessary for the fulfilment of the statistical purposes.
Right to object to direct marketing: Where personal data are processed for the purpose of carrying out direct marketing activities, you have the right to object at any time to the processing of personal data relating to you for the purpose of such marketing activities, including profiling, insofar as it relates to such direct marketing activities. In the event of an objection to processing for the purposes of direct marketing, we shall no longer process the personal data concerned for those purposes.
To exercise your right of objection, you can contact us at any time by e-mail at dpo@ada.com.
-Right of access: As a data subject, you have a right of access under the conditions of Article 15 GDPR. This means in particular that you have the right to request confirmation from us as to whether we are processing personal data relating to you. If this is the case, you also have a right of access to this personal data and to the information listed in Article 15 (1) GDPR. This includes, for example, information about the purposes of the processing, the categories of personal data processed and the recipients or categories of recipients to whom the personal data have been or will be disclosed.
-Right to delete/"right to be forgotten": As a data subject, you have a right of deletion ("right to be forgotten") under the conditions laid down in Article 17 GDPR. This means that you are in principle entitled to demand that we delete personal data relating to you without delay and we are obliged to delete personal data without delay if one of the reasons listed in Article 17 (1) GDPR applies. You can do this at any time, for example, by deleting your account. If we have made the personal data public and we are obliged to delete them, we are also obliged, taking into account the available technology and the implementation costs, to take reasonable measures, including technical measures, to inform other data controllers who process the personal data that a data subject has requested that all links to these personal data or copies or replications of these personal data be deleted (Article 17 (2) GDPR). The right to erasure ("right to be forgotten") does not apply by way of exception if the processing is necessary for the reasons listed in Article 17 (3) FADP. This may be the case, for example, if the processing is necessary for the fulfilment of a legal obligation or for the assertion, exercise or defence of legal claims (Article 17 (3) (a) and (e) FADP).
-Right to restrict processing: As a data subject, you have a right to restrict processing under the conditions of Article 18 GDPR. This means that you have the right to demand that we restrict processing if one of the conditions listed in Article 18 (1) GDPR is met. This may be the case, for example, if you dispute the accuracy of the personal data. In this case, the processing will be limited for a period of time that allows us to verify the accuracy of the personal data (Article 18 (1) (a) FADP). Restriction means the marking of stored personal data with the aim of restricting their future processing (Article 4 (3) GDPR).
-Right to data transferability: As a data subject, you have a right to data transferability under the conditions laid down in Article 20 GDPR. This means that, in principle, you have the right to receive the personal data relating to you which you have provided us with in a structured, common and machine-readable format and you have the right to transfer this data to another controller without hindrance from us, provided that the processing is based on consent pursuant to Article 6 (1) (a) or Article 9 (2) (a) GDPR or on a contract pursuant to Article 6 (1) (b) GDPR and the processing is carried out by means of automated procedures (Article 20 (1) GDPR). In exercising your right to data transferability, you also have the right to request that personal data be transferred directly from us to another responsible party, insofar as this is technically feasible (Article 20 (2) FADP).
-Right of rectification: As a data subject, you have a right of rectification under the conditions of Article 16 of the GDPR. This means in particular that you have the right to demand that we correct incorrect personal data relating to you without delay and complete incomplete personal data.
-Right of appeal: As a data subject, you have the right to appeal to a supervisory authority under the conditions of Article 77 of the GDPR. The supervisory authority responsible for us is the Berlin Commissioner for Data Protection and Freedom of Information (Friedrichstr. 219, 10969 Berlin, telephone: 030 13889-0; e-mail: mailbox@datenschutz-berlin.de).
If you request us to stop processing your personal data or to delete them, this will mean that you will no longer be able to use our services or at least those parts of the services which require the processing of the types of personal data you have asked us to delete, which may mean that you will no longer be able to use the services as a whole.
8. Changes to this privacy policy
Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email or by notification via the App. Therefore, we encourage you to check the App from time to time so that you are kept informed of how we are processing your information.