1. Our Commitment to Your Privacy
Nerigame Geriatric Hospital (“the Hospital,” “We,” “Us,” “Our”), located at [Specific Address, City, Assam, India], is deeply committed to protecting the privacy and confidentiality of our patients, their families, representatives, visitors, and users of our services (“You,” “Your”). As a healthcare provider specializing in geriatric care, we understand the sensitivity of personal and health information. This Privacy Policy outlines how we collect, use, disclose, process, store, secure, and manage Your Personal Information, including Sensitive Personal Data or Information (SPDI), in compliance with applicable Indian laws and regulations.
2. Scope and Consent
This policy applies to all Personal Information and SPDI collected by the Hospital through any means, including:
- During registration, admission, consultation, treatment, and discharge processes.
- Through interactions with our medical and administrative staff.
- Via our website, mobile applications, or other digital platforms (if applicable).
- From authorized representatives acting on behalf of a patient.
- From third parties like referring physicians or diagnostic labs (where legally permissible).
By availing our services, providing your information, or permitting an authorized representative to do so, You consent to the collection, storage, processing, disclosure, and transfer of Your Personal Information (including SPDI) in accordance with the terms of this Privacy Policy
3. Definitions
- Personal Information (PI):Any information relating to an identified or identifiable natural person. This includes name, address, contact details, date of birth, etc.
- Sensitive Personal Data or Information (SPDI):As defined under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (SPDI Rules), this includes information relating to:
- Passwords;
- Financial information such as bank account or credit card details;
- Physical, physiological, and mental health conditions;
- Sexual orientation;
- Medical records and history;
- Biometric information;
- Any detail relating to the above clauses provided to us for service provision;
- Any information received under the above clauses by us for processing, stored or processed under lawful contract or otherwise.
- Data Principal:The individual to whom the personal data relates (the Patient/User).
- Data Fiduciary:Nerigame Geriatric Hospital, which determines the purpose and means of processing personal data.
- Processing:Includes activities like collection, recording, storage, use, disclosure, transfer, erasure, etc., of data.
4. Information We Collect
We may collect various types of information, including but not limited to:
- Personal Identifiers:Name, age, gender, date of birth, address, phone number, email address, emergency contact details, photograph, government-issued ID details (e.g., Aadhaar, Voter ID – collected only where necessary and legally permitted).
- Health Information (SPDI):Medical history, pre-existing conditions, allergies, medications, symptoms, examination findings, diagnostic test results (lab reports, imaging), treatment plans, surgical history, mental health information, doctor’s notes, discharge summaries.
- Financial Information (SPDI):Billing details, insurance policy information, payment card details (processed securely through payment gateways), bank account details (for refunds).
- Information from Representatives:Name, contact details, relationship to the patient, proof of authorization.
- Technical Information (if applicable):IP address, browser type, operating system when interacting with our website or digital platforms.
5. How We Collect Information
We collect information:
- Directly from You:When you fill forms, during consultations, provide medical history, make payments, or communicate with us.
- From Authorized Representatives:When a family member or legally appointed guardian provides information on behalf of a patient (especially relevant for geriatric patients who may need assistance).
- During Medical Care:Through examinations, diagnostic tests, and treatment administered by our healthcare professionals.
- From Third Parties:Such as referring doctors, previous hospitals/clinics (with Your consent where required), diagnostic laboratories, and insurance providers.
- Automatically:Through cookies and similar technologies if you use our website or apps (refer to separate Cookie Policy if applicable).
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6. Purpose of Collection and Use of Information
We collect and use Your Personal Information (including SPDI) for the following legitimate purposes:
- Provision of Healthcare Services:To diagnose, treat, provide nursing care, manage your health condition, and provide continuity of care.
- Hospital Operations & Administration:Scheduling appointments, managing admissions/discharges, maintaining medical records, billing and payment processing, managing insurance claims.
- Communication:Contacting you regarding appointments, test results, treatment updates, billing information, and follow-up care.
- Identification and Verification:Confirming your identity.
- Legal and Regulatory Compliance:Complying with applicable laws, regulations, reporting requirements (e.g., notifiable diseases), court orders, and responding to government/statutory authorities.
- Quality Improvement:Internal audits, quality assessment activities, training, improving our services (data used for these purposes will be anonymized or pseudonymized where feasible).
- Research:For clinical or academic research purposes, only with Your explicit separate consent or after the data has been fully anonymized.
- Safety and Security:Ensuring the safety and security of patients, staff, and visitors within the hospital premises.
7. Disclosure and Transfer of Information
We do not sell or rent Your Personal Information. We may disclose or transfer Your information only in the following circumstances and on a need-to-know basis:
- Internally:To doctors, nurses, technicians, and administrative staff directly involved in providing Your care or managing hospital operations.
- To Other Healthcare Providers:To referring physicians, specialists, diagnostic labs, or other hospitals/clinics involved in your continuum of care, typically with your consent or as necessary for treatment.
- To Authorized Representatives:To family members or legal guardians designated by you or legally authorized to receive information about your care.
- To Insurance Companies/TPAs:For processing insurance claims, as authorized by you.
- To Third-Party Service Providers:Who perform services on our behalf (e.g., IT support, payment processors, auditors), under strict confidentiality agreements and data protection obligations.
- As Required by Law:To law enforcement agencies, courts, government bodies, or regulatory authorities when mandated by law or legal process.
- In Emergencies:To protect the vital interests (life or health) of the patient or another person.
Transfers outside India, if any, will only occur in compliance with applicable Indian laws.
8. Data Security
We implement reasonable security practices and procedures as required by the SPDI Rules and consistent with industry standards. This includes technical, physical, and administrative safeguards to protect Your Personal Information from unauthorized access, disclosure, alteration, loss, misuse, or destruction. Measures include:
- Access controls and authentication.
- Secure storage of physical and electronic records.
- Data encryption (where appropriate).
- Regular security assessments.
- Staff training on privacy and confidentiality.
- Confidentiality agreements with employees and third parties.
However, no system is completely secure, and we cannot guarantee absolute security.
9. Data Retention
We retain Your Personal Information, especially medical records, for as long as necessary to fulfill the purposes outlined in this policy and as required by applicable laws and medical record retention guidelines in India. After the retention period, we will securely destroy or anonymize the information.
10. Your Rights (Data Principal Rights)
Subject to applicable laws, You have the following rights regarding Your Personal Information:
- Right to Access:You can request access to the Personal Information we hold about you.
- Right to Correction & Erasure:You can request correction of inaccurate or incomplete information. You may request erasure under certain circumstances as permitted by the DPDP Act.
- Right to Information:You have the right to know what information is being collected and how it is processed.
- Right to Withdraw Consent:You can withdraw your consent for processing your SPDI at any time by contacting our Grievance Officer. Withdrawal will not affect the lawfulness of processing based on consent before its withdrawal. However, withdrawal may affect our ability to provide certain services.
- Right to Grievance Redressal:You have the right to register a grievance if you are concerned about the handling of your data.
- Right to Nominate:You may have the right to nominate another individual to exercise your rights in case of your death or incapacity (as per DPDP Act provisions).
To exercise these rights, please contact our Grievance Officer in writing. We will respond to your request in accordance with applicable laws.
11. Role of Representatives
- We acknowledge that due to age or health conditions, many of our geriatric patients rely on family members or legally appointed representatives. We will interact with authorized representatives and share information necessary for the patient’s care, provided appropriate authorization/consent is in place or implied by the circumstances (e.g., emergency). Representatives are also expected to respect the patient’s privacy rights.
12. Cookies and Website Privacy
- If the Hospital operates a website or mobile application, a separate policy detailing the use of cookies, tracking technologies, and online data collection practices may be provided.
13. Policy Updates
- We reserve the right to update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The updated policy will be made available at the Hospital premises and/or on our website (if applicable). We encourage you to review this policy periodically.
14. Grievance Officer
In compliance with the SPDI Rules and the DPDP Act, we have appointed a Grievance Officer to address any concerns or grievances regarding your privacy and data protection:
- Name/Designation: Dr. Kamal Malla Buzarbaruah
- Email:care@nerigame.com
- Phone Number +91 361 2914507
Address: GNB COMPLEX, BLOCK B, Suderashan Public School Rd, Jaya Nagar, Khanapara, Guwahati, Assam 781022
Please contact the Grievance Officer in writing for any privacy-related questions, concerns, or requests to exercise your rights.
15. Governing Law
- This Privacy Policy shall be governed by and construed in accordance with the laws of India. Any disputes arising under this policy shall be subject to the exclusive jurisdiction of the competent courts Guwahati, Assam.
