Privacy Notice.
Effective Date: January 1, 2025
Spine & Sport Bermuda (“we”, “us”, “our”) is committed to protecting and respecting your privacy. This Privacy Notice explains how we collect, use, disclose, and safeguard your personal data in compliance with the Bermuda Personal Information Protection Act 2016 (PIPA). It also outlines your individual rights to data privacy.
We collect the following data:
Personal Identification Information: name, address, email address, phone number, etc.
Emergency / next of kin name and contact information
Medical Information: health records, medical history, treatment details, referring physician, etc.
Financial Information: insurance information, billing, etc.
Technical data: IP address, browser type.
How do we collect your data?
You directly provide Spine & Sport Bermuda with most of the information we collect when you:
Schedule an appointment with us.
Contact us via our website.
Complete and submit a new patient information form.
Consent to have medical tests done as recommended by our physicians.
Use or view our website via your browser’s cookies.
We may also receive your data from the following sources:
Your referring health professional or general physician.
Laboratories where you have completed medical tests.
Hospitals where you have undergone procedures.
Other doctors or specialists you have visited for treatment.
Health insurance providers.
How We Use Your Information
We use personal information so that we can:
Provide you with healthcare and treatment.
Process payments and insurance claims and manage your account.
To communicate with you regarding your treatment and appointments.
Enhance our services and website functionality.
Comply with legal and regulatory requirements.
Sharing your information
We share your information with:
Healthcare providers and related service providers involved in your care.
Insurance companies for billing purposes.
Third-party service providers who assist us in our operations in alignment with PIPA and under strict confidentiality agreements.
Regulatory bodies as required by law.
Conditions for processing personal information
We will only process your personal information with your consent, except where required or permitted by law. By providing us with your personal information, you agree to its collection, use, and disclosure as outlined in this Privacy Notice. You have the right to withdraw your consent at any time by contacting us. Please note that withdrawing consent may affect our ability to provide you with healthcare and other services.
Privacy of Children
Under PIPA, a child is defined as an individual under the age of 14. Children’s personal information has increased protection under PIPA.
Spine & Sport Bermuda is committed to protecting the privacy of children. We do not knowingly collect personal information from children under the age of 14 without the consent of a parent or legal guardian. If it comes to our attention that we have collected personal information from a child without proper consent, we will take immediate steps to delete such information from our records.
Parents or guardians who believe their child may have provided us with personal information without their consent are encouraged to contact us promptly so that we can address the matter.
Closed-Circuit Television (CCTV)
We use CCTV to monitor our premises to help maintain a safe and secure environment for our visitors, patients and employees.
Cameras are in public areas only (I.E., reception area, hallway).
We do not use covert monitoring or surveillance.
Signs are displayed at the entrance to our premises.
Purposes of our CCTV System:
The personal safety of our employees, patients and visitors to our practice;
To support our health and safety measures;
To support law enforcement in the prevention, detection and prosecution of crime; and
To protect our premises and assets (including personal information) and those of our employees and patients from damage, disruption, vandalism and other crime.
Conditions for Processing:
We will not process CCTV footage unless it captures criminal activity, a security matter or a health and safety incident.
We may need to use this personal data to establish, exercise or defend against legal claims.
Access and Disclosure
Access to recorded CCTV footage is restricted to approved members of staff whose role requires them to have access to such data.
CCTV footage will only be accessed or disclosed if it is necessary to deal with an incident which falls within the purposes identified above or to respond to an individual request.
CCTV data will only be disclosed to a third party where there is a lawful reason or where required by law.
CCTV footage will not be accessed or used for any other purpose.
Retention and Security
CCTV footage is kept for 14 days when it is automatically erased unless required, for a specific investigation (such as criminal damage when it will be kept only for the duration of that investigation).
We have security measures in place to protect CCTV data.
How do we store your information?
We retain your personal information as long as necessary for the purposes outlined or as required by law, to comply with data privacy legislation.
Data is stored at our practice located on the 3rd Floor Mechanics’ Building, 12 Church St., Hamilton HM 11. The building is monitored by an alarm system
All personal data is stored digitally in a HIPAA-compliant, password-protected database.
We manage the access of these files.
We retain data for 7 years after a patient has died or left the practice, as required by law.
After 7 years, patient files are made inactive.
Hard copies of personal information are shredded and disposed of.
Security of Information
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These security measures include:
Secure IT systems and data storage.
Regular security reviews and employee training.
Encryption and controlled access to sensitive data.
Physical security measures including locked premises, CCTV and access control systems.
Your data privacy rights
Every patient is entitled to the following:
The right to be informed - you have the right to know the purposes for which we collect your personal information, how it will be used, and whether it will be shared with third parties.
The right to access - you have the right to ask us for copies of your personal information and/or medical records. This right always applies. We may charge a small fee for this service.
The right to rectification - you have the right to ask us to correct any information you think is inaccurate. You also have the right to ask us to complete information you believe is incomplete.
The right to restrict processing - you have the right to request that we restrict the processing of your personal information in certain circumstances (e.g. the accuracy of the information is contested).
The right to lodge a complaint - you can file a complaint with Bermuda's Privacy Commissioner if you believe your rights have been violated or if we have failed to comply with PIPA.
Cookie Policy for Spine & Sport Bermuda
What Are Cookies
Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our website, we may collect information from you automatically through cookies or similar technology.
For further information, visit allaboutcookies.org.
Disabling Cookies
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore, it is recommended that you do not disable cookies.
The Cookies We Use
Forms-related cookies - When you submit data to us through a form such as those found on contact pages or comment forms, cookies may be set to remember your user details for future correspondence.
Site preferences cookies - We use these cookies so that we recognise you on our website and remember your previously selected preferences.
Third-Party Cookies
In some special cases we also use cookies provided by trusted third parties. The following section details which third-party cookies you will encounter on this website.
This site uses Google Analytics which is one of the most widespread and trusted analytics solutions on the web to help us understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.
For more information on Google Analytics cookies, see the official Google Analytics page.
Third party analytics are used to track and measure usage of this site so that we can continue to produce engaging content. These cookies may track things such as how long you spend on the site or pages you visit which helps us understand how we can improve the site for you.
We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work the following social media sites including Facebook, Instagram, X, and Linked In will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.
Privacy notices of other websites
Our website contains links to other websites and social media sites. Our privacy notice applies only to our website. If you choose to follow those links, please remember to check the privacy notices at those sites.
Changes to this privacy notice
We may update this Privacy Notice from time to time. Any changes will be posted on this page with an updated revision date. This notice was last updated on December 30, 2024.
Contact Us
If you have any questions about our Privacy Notice, the information we hold on you, or you would like to exercise one of your data protection rights, please contact:
Dr. Reid Robinson
Privacy Officer
Spine & Sport Bermuda
3rd Floor Mechanics Building
12 Church Street
Hamilton HM 11
How to contact the appropriate authority
If you want to make a complaint or if you feel that Spine & Sport Bermuda has not addressed your concern in a satisfactory manner, you can contact the Privacy Commissioner of Bermuda at:
(441) 543 7748
Maxwell Roberts Building, 4th Floor, 1 Church Street, Hamilton HM11