Exeevo and Privacy
Exeevo Inc. is committed to the individual’s right to privacy. This Privacy Statement applies to all Affiliates, Websites and Services owned and operated by Exeevo and describes our privacy practices for how we collect, use, share and process information relating to individuals (“Personal Data”), and how you can learn about your rights and choices regarding our processing of your Personal Data. As a global organization, we abide by all applicable data privacy laws, such as the California Consumer Privacy Act (“CCPA”), the European Union’s General Data Protection Regulation (“GDPR”), the US Health Insurance Portability and Accountability Act (“HIPAA”) and Brazil’s Lei Geral de Proteção de Dados (“LGPD”). Each of these laws focuses on transparency and trust.
Protection of personal data/protected health information (PHI)/personally identifiable information (PII) is important to Exeevo and its clients.
This policy is intended to be shared with our clients, vendors, business associates and employees so that they are aware of the policies and practices with respect to personal data/PHI/PII managed by Exeevo as part of any services delivered.
Exeevo is committed to protect personal information in accordance with its responsibilities under various regulatory frameworks and individual rights. As a healthcare solutions company, Exeevo’s leadership, management, employees and its business associates shall strive to protect personal information by:
- Identifying internal and external interested parties and the extent to which they are involved in the governance of the organization’s personal information management system
- Providing best-in-class resources and methods to process personal information lawfully, fairly and in a transparent manner in relation to the rights of data principles or data subjects
- Safeguarding the personal information by collecting, processing, storing and transmitting in forms that permit identification of individuals for nothing other than explicit, specified purposes
- Providing clear information to natural persons (including special safeguards while collecting information from children) about how their personal information can be used and by whom; and by respecting individual’s rights in relation to their personal information
- Assuring that further processing or archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes shall not be considered to be incompatible with the initial purposes
- Processing in a secure manner that ensures protection against unauthorized or unlawful processing and against accidental loss, destruction or damage
- Taking adequate steps to establish that the personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed
- Taking reasonable steps to ensure accuracy of the personal information
- Following best practices for safe data storage, transmission and destruction
- Implementing appropriate backup and disaster recovery systems
- Responding to personal data breaches in the most appropriate and fastest manner possible: In the events such as accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, Exeevo shall promptly assess the risk to individual’s rights and freedoms and report such breach to the Data Protection Cell (Refer to section 5:Governance Structure for Personal Data Protection) for taking further actions as per the regulatory requirements
General Provisions to This Policy:
- Applicability: This policy is applicable to all personal information processed at Exeevo.
- Ongoing Compliance: The Data Protection Cell shall be responsible for Exeevo’s compliance with this policy.
- Cognizance: This policy shall be made available to all employees and associates of Exeevo as documented information and shall also be communicated appropriately. This policy shall be made aware to all of Exeevo’s employees, its associates, and interested parties effectively. Review: This policy shall be reviewed at least once annually.
- This policy applies to all personal data/PII and PHI processed by Exeevo.
- This policy would be relevant to all applicable services or projects managed for Exeevo’s clients.
Business Associate Agreement
Refers to the agreement between the business associate (Exeevo) and the covered entity.
Business Unit (BU)
Refers to different departments in Exeevo.
Refers to an organization that routinely handles personal information, PII, and PHI.
Data Protection Officer (DPO)
Refers to the person heading all data privacy-related programmes and initiatives within the organization.
Refers to the project, programme or engagement conducted or performed by Exeevo on behalf of its clients or covered entity.
Electronic Protected Health Information (EPHI)
Refers to all individually identifiable health information that is created, maintained or transmitted electronically.
General Data Protection Regulation (GDPR)/(EU) 2016/679
Legal framework that sets guidelines for the collection and processing of personal information of individuals within the European Union (EU).
Health Insurance Portability and Accountability Act (HIPAA)
Act of 1996 that specifies laws for the protection and use of personal (or protected) health information (PHI), which is essentially an individual’s medical records.
Personal identifiable information (PII)
Refers to any data that could potentially identify a specific individual. Any information that can be used to distinguish one person from another and can be used for de-anonymizing anonymous data can be considered as PII. Any information about an individual’s identity such as their name, social security number, date and place of birth, mother’s maiden name and biometric records can be considered as PII.
PII also can constitute “PHI” under HIPAA Act of 1996.
Refers to the part of the HIPAA rule that addresses the saving, accessing and sharing of medical and personal information of an individual, including a patient’s own right to access.
Refers to any information that identifies an individual AND relates to:
- The individual’s past, present or future physical or mental health; OR
- The provision of healthcare to the individual; OR
- The past, present or future payment for healthcare.
Privacy Single Point of Contact (SPOC)
Refers to the person monitoring the personal data/PII/PHI management under each BU.
Refers to the part of the HIPAA rule that outlines national security standards intended to protect health data created, received, maintained or transmitted electronically.
Refers to the single point of contact/point persons.
Preselected website that can automatically send updated information for immediate display or viewing on request.
Special categories of personal information
The following types of data are categorized as special categories of personal information:
- Racial or ethnic origin
- Political opinions
- Religious or philosophical beliefs
- Trade-union membership
- The processing of genetic information
- Biometric information for the purpose of uniquely identifying a natural person
- Information concerning health or information concerning a natural person’s sex life or sexual orientation.
High-risk personal information
The following types of data are categorized as high risk personal information:
- Special category personal information
- Personal bank account and other financial information;
- National identifiers, such as national insurance numbers;
- Personal information relating to vulnerable adults and children;
- Detailed profiles of natural persons (including children); and
- Sensitive negotiations which could adversely affect natural persons.
5. GOVERNANCE STRUCTURE FOR PERSONAL DATA PROTECTION
Data Privacy Cell
Exeevo shall ensure appropriate governance of personal data/PII/PHI. In pursuance of this objective, a personal data privacy cell has been structured as shown below:
Data privacy cell consists of DPO and all the BU-SPOCs.
- To identify personal data/PII/PHI under all operations and projects across Exeevo
- To analyze risks and implement control measures to protect personal data/PII/PHI
- To provide a support framework to manage the rights of data subjects
- To address requests and grievances of data subjects
- To ensure compliance with the data privacy requirements of data controllers
- To ensure compliance with various legal and regulatory requirements across jurisdictions
- To provide adequate measures for data privacy with processors/subprocessors as required
- To provide for appropriate technology and operational controls for transfer / import / export / storage / destruction of personal data / PII / PHI
The summary of proceedings of data privacy governance shall be discussed in the quarterly Information Security Group review meeting.
6. SOURCES OF PERSONAL DATA/PII/PHI
The methods and technologies by which the personal data/PII/PHI are collected are as follows:
Collection of Personal Data/PII/PHI Directly From the Individual
In the instance where Exeevo collects personal data/PII/PHI about an individual, measures shall be taken to respect the privacy preferences of the individual.
Personal data/PII/PHI is collected from participants in an engagement who access Exeevo websites, portals, platforms, etc. We may collect additional information relating to an individual’s participation in Exeevo programmes. Please note that we also collect personal data/PII/PHI relating to an individual at the time of enrolling in an Exeevo programme, as well as in the course of allocating and issuing a unique ID and password to access the Exeevo websites, portals, platforms, etc.
Automatic Collection of Information
When an individual visits an Exeevo website, we automatically collect and analyze certain information about the individual’s computer. This information includes, but may not be limited to the Internet Protocol (IP) address used to connect the individual’s computer to the Internet, information about the browser type and language, the date and time the individual accessed the website, the content of any undeleted cookies that the browser previously accepted from Exeevo and the referring website address.
Cookies and Other Technologies
We use various technologies to collect information on an Exeevo website. Cookies: When an individual visits an Exeevo website, we may assign the computer one or more “cookies.” A cookie is a small text file that contains information that can later be read by Exeevo to facilitate access to the site and personalize the online experience. For example, when an individual signs into an Exeevo site, we may record his/her user ID in a cookie file on the individual’s computer. In addition, through the use of a cookie, we may automatically collect information about the online activity on Exeevo site, such as the web pages visited, the links clicked and the searches conducted. Most browsers automatically accept cookies; however, an individual can usually modify the browser setting to decline cookies by visiting the Help section of the browser’s toolbar. If an individual chooses to decline cookies, please note that he/she may not be able to sign in or use some of the interactive features offered on Exeevo websites.
7. MANAGING DATA PRIVACY RIGHTS IN PROJECTS
The scope of business at Exeevo does not require us to disclose personal data/PII/PHI to any parties out of designated programme area except for legal and statutory obligations.
Before the initiation of a project, we ensure that:
- The business SPOC is communicated regarding the project/programme
- Contract-specific clauses for the project/programme are reviewed and monitored
- Risk analysis and treatment is carried out for the complete programme/project and contingency and mitigation is put in place
- Each and every member of the programme/project shall be responsible to ensure the PII/PHI is kept confidential
- Access to the entire or limited PII/PHI, based on their role in the engagement should be restricted
- We recognize the covered entities that are to be provided access to the PII/PHI in a de-identified format
- Any third parties who have access to the PII/PHI comply with Exeevo’s policies and give proof of compliance
- The respective privacy SPOC of the team should provide reports to the DPO on updates, problems, and breaches with regard to PII/PHI
- The BU SPOC ensures that all the team members are trained with information of do’s and don’ts of the data
8. MANAGING DATA PRIVACY RIGHTS FOR PERSONAL DATA/PII/PHI COLLECTED FROM WEBSITES AND OTHER ONLINE CHANNELS
In general, any individual may access Exeevo websites or online channels without providing any personal information about themselves. However, we collect certain information such as:
- Information that is provided via our websites, including information provided when an individual registers on our website, for example, name, email address, designation, company, country and telephone number
- Information about an individual’s computer, visits and the use of Exeevo websites, such as IP address, demographics, computer’s operating system, and browser type and information collected via cookies.
Use of Personal Information
We may use the personal information we obtain to:
- Provide and administer our products and services
- Communicate about and administer our products, services, events, programmes and promotions (such as by sending alerts, promotional materials, newsletters and other marketing communications)
- Conduct and facilitate surveys, sweepstakes, focus groups and market research initiatives
- Perform data analytics (such as market research, trend analysis, financial analysis and customer segmentation)
- Provide customer support
- Process, evaluate and respond to requests, inquiries and applications
- Operate, evaluate and improve our business (such as by administering, enhancing and improving our products and services; developing new products, services and online channels; managing our communications and customer relationships; and performing accounting, auditing, billing, reconciliation and collection activities)
- Maintain and enhance the safety and security of our products, services, online channels, network services, information resources and employees
We may combine personal information we obtain through online channels with information we obtain through offline channels, as well as other information, for the purposes described above. We may anonymize or aggregate personal information and use it for the purposes described above and for other purposes to the extent permitted by applicable law. We also may use personal information for additional purposes that we identify at the time of collection. We obtain the individual’s/data subject’s consent for these additional uses to the extent required by applicable law.
Consequences of Not Providing Personal Data/PII/PHI
If an individual/data subject chooses not to provide their personal information that is mandatory to process a request, then, Exeevo may not be able/restricted from providing the corresponding service.
9. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA AND THE LEGAL BASIS
The purposes are programme/project specific. However, the common purposes are mentioned as follows:
- We process personal data/PII/PHI when it is necessary for the performance of a contract to which the individuals/data subjects are the party or in order to take steps at a request prior to entering into a contract. This applies in any case where we provide services to a client in pursuance to a contract, such as when an individual/data subject uses our website or processes for registration on the websites/online channels.
- We process the personal data/PII/PHI when it is necessary for the purposes of a legitimate interest pursued by us or a third party (when these interests are not overridden by the data protection rights and regulatory obligations). This applies in the following circumstances:
- To identify the individuals/data subjects
- To contact and respond to the individual’s questions or requests
- To provide access to desirable content and/or services based on preferences/contractual obligations
Sharing of Personal Data/PII/PHI
In general, our clients are the data controllers responsible for processing the personal data/PII/PHI.
Transfer of Personal Data/PII/PHI Outside the European Economic Area (EEA)
We transfer personal information to countries outside the EEA (generally referred to as third countries) only if included in our contractual agreement that we have signed with the client, including to countries which have different data protection standards to those which apply in the EEA. Our service providers are primarily located in the United States, Singapore, India and the United Kingdom. Where service providers process personal data/PII/PHI in countries deemed adequate by the European Commission, we rely on the European Commission’s decision to protect personal information.
For transfers to Exeevo group companies and service providers outside the EEA, we use standard contractual clauses or rely on a service provider’s Privacy Shield certification or a service provider’s (EU Data Protection Authority approved) corporate rules that are in place to protect the personal data/PII/PHI.
When required, Exeevo discloses personal data/PII/PHI to external law enforcement bodies or regulatory authorities to comply with legal obligations
Access, Correction, Objection With Regard to Personal Data/PII/PHI
Data subjects have the rights to request access to correct, delete or transfer personal data/PII/PHI that we hold, including profile and preferences. Data subjects also have the rights to object to certain processing and, where our client or we have asked for the consent to process the personal data/PII/PHI, to withdraw this consent.
Where we process the personal data/PII/PHI because we have a legitimate interest in doing so, data subjects also have a right to object this. These rights may be limited in some situations, for example, where we can demonstrate that we have a legal requirement to process the personal data/PII/PHI.
Data subjects can assert their rights where such information was provided by contacting us at email@example.com.
United States residents can contact us at the below mentioned address and phone number as well
Exeevo, Inc. Office Address: 600 Third Avenue, 2nd Floor, New York, NEW YORK, 10016
Board line Number: +1 732 750 2901
Exeevo adopts reasonable and appropriate security practices and procedures including administrative, physical security and technical controls to safeguard the personal information.
We take precautions including organizational, technical and physical measures to help safeguard against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, the personal data/PII/PHI we process or use.
Data Retention and Destruction
Exeevo will retain the personal data/PII/PHI as per the project/programme agreement. On the completion of agreed period, the data shall be archived/destroyed/transmitted to client according to the regulatory norms.
If the client wishes to retain the personal data/PII/PHI, the client’s employee identified in the statement of work or service agreement should request for the data in writing. Exeevo will provide the data in the prescribed format.
Reference document: Sections 6.5 and 8 of Exeevo Information SOP For Exeevo Information Lifecycle Document.
Children’s Personal Information
We do not knowingly collect personal data/PII/PHI from children under the age of 16. If the parents or guardians believe that their child/ward has provided us with personal data without their consent, such parents or guardians can contact us at firstname.lastname@example.org and we will take steps to delete such personal data/PII/PHI from our systems
Restrictions on Automated Processing and Decision Making With Significant Effects on the Data Subject(s)
Restrictions on automated processing of data and decisions based solely on automated processing without human intervention (which could include profiling) shall apply if the decisions produce legal effects or similar significant effects on the data subject, individuals have a right to object to automated decision making.
Automated processing of data may be used if it is:
Necessary to enter into, or to perform, a contract between a data subject and controller
Authorized by Union or Member State law
Based on the individual’s explicit consent
We share personal data/PII/PHI (as per business needs) with:
Exeevo Data Breach Notification procedure
BS 10012:2017 Standard (specification for Personal Information Management System)
GDPR ([EU] 2016/679)
California Consumer Privacy Act, AB-375 (2017–2018 Session)
11. APPENDIX-1 RESPONSIBILITIES OF KEY STAKEHOLDERS
Exeevo DPO shall be responsible for the development and implementation of policies and procedures that are designed to achieve ongoing compliance with global laws with regard to PII/PHI. The responsibilities of a DPO are as follows:
- Establishing data privacy and data protection objectives
- Designating data privacy point persons (SPOCs) for every BU
- Ensuring adequacy of the data privacy/data protection framework across the enterprise
Responsibilities of Data Privacy SPOCs (BU)
The point persons/SPOCs shall be responsible for data privacy/protection for the respective BUs that they are assigned with. The responsibilities include:
- Performance of risk assessment before the on boarding of a project or an engagement on the personal data/PII/PHI collected, maintained, used, stored or transmitted, based on GDPR, HIPAA and other applicable data protection regulations
- Determination of the physical, administrative, operational and technical controls that may be necessary to adequately address the identified risks, based on the risk assessment
- Implementation of controls after on boarding the engagement/project as defined in the risk assessment documentation
- Maintenance of engagement-specific risk assessment documentation
- Monitoring for adherence with approved and permitted methods of collection, processing, storage and transmission of personal data/PII/PHI
- Directing an individual’s/data subject’s rights-related requests to email@example.com
Contact Information in Case of Questions, Concerns or Complaints