Virco - Diagnostic Privacy Policy

This Privacy Policy applies to Virco BVBA and VircoLab Inc. and all of their subsidiaries (hereinafter referred to as "Virco").

Virco provides diagnostic services to Medical Professionals in connection with clinical care or research activities in the field of infectious diseases. Further explanation about Virco and its diagnostic services can be found on Virco's website www.vircolab.com.

Only authorized Medical Professionals may submit a request for diagnostic services. Medical Professionals, please read this entire Privacy Policy before submitting a request for a diagnostic service.

Scope

This Privacy Policy generally describes our practices regarding the use and processing of any samples, Personal Data and Personal Medical Information obtained from Medical Professionals in the course of providing diagnostic services, whether for clinical or research purposes.

Definitions

For the purpose of this policy, the following terms are defined in more detail:

Personal Data: means any information relating to an identified or identifiable individual. An identifiable individual includes an individual who can be identified, directly or indirectly (for example, by reference to an identification number, whether assigned by a government agency, health care provider, entity responsible for payment for health care, or other entity). Personal Data may relate to Medical Professionals or their patients.
Personal Medical Information: means Personal Data that relates to the health status of an individual, the provision of health care to an individual, or the payment for the provision of health care to the individual. Personal Medical Information will relate to patients only.
Medical Professional: means any individual who provides health care; is subject to licensing, professional and ethical obligations; and is authorized to order and receive the results of the diagnostic services provided by Virco. Medical Professionals include medical doctors and physician assistants.
Processing: means any use or disclosure of Personal Data, such as: collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.
Ethics & Privacy Board: means a group of experts in the field of Bio-Ethics and/or Privacy who advise on preferred approaches to research activities to ensure compliance with all legal requirements and best practices.

Consent of the Medical Professional and the patient

By requesting a diagnostic service from Virco, the Medical Professional and the patient agree to the terms of this Privacy Policy. The ordering Medical Professional warrants and represents that he/she has made all legally required disclosures and that he/she possesses consents and/or the competent IRB/EC(*) authorizations or permissions for Virco's use of the patient's samples and the processing of the patient's Personal Medical Information or other Personal Data for the purposes as agreed upon.

Pursuant to the Service Agreement that a Medical Professional ordering diagnostic services must enter into with Virco, the Medical Professional consents to Virco's processing of his/her Personal Data.

Commitment of Virco to protect Personal Medical Information and other Personal Data

Virco is committed to protecting the privacy of those who entrust us with their Personal Medical Information and other Personal Data. Our employees have been trained to uphold this commitment. In furtherance of our commitment, we have taken reasonable and appropriate steps to comply with all applicable data protection, security and privacy laws and regulations.

(*) IRB: Institutional Review Board - EC: Ethics Committee

Information you provide

The ordering Medical Professional may be asked to provide his/her own Personal Data and the Personal Data and Personal Medical Information about a patient when this information is needed to perform the diagnostic service. Alternatively, the ordering Medical Professional may request Virco to accept such Personal Medical Information and/or other Personal Data due to customer reporting requirements, reimbursement prerequisites, or as part of provision of the service requested e.g., historical reporting.

Virco will only process relevant data required in provision of a specific service and will handle any relevant Personal Data and/or Personal Medical Information only in relation to the purposes for which they are collected, ensuring an appropriate level of confidentiality and security.

Use and disclosure of information

Samples, Personal Medical Information, Personal Data and Samples submitted to us will be used or processed only for the following purposes:

Virco's diagnostic services
operation of laboratories;
supporting activities of the standard laboratory operations (e.g. quality assurance);
information exchange with the ordering Medical Professional or the referring laboratory retained by the Medical Professional.;
collaboration with other health care providers who are requested by Virco to execute specialized parts of the diagnostic service (these companies will be required to comply with Virco's Privacy Policy);
payment - including billing and reimbursement;
improvement of diagnostic services;
research activities by Virco, endorsed by an Ethics & Privacy Board. To leave no doubt, research staff will only have access to consented information void of Personal Data. In the event that, following the appropriate consent and/or authorizations, sample left-overs may be transferred to research staff for research activities, Personal Data which make the patient readily identifiable will be removed.
judicial and administrative proceedings, for law enforcement, court orders or other regulations, e.g. regulatory inspections or audits.

Patient's and Medical Professional's privacy rights

Right to a copy: Any patient or ordering Medical Professional has the right to request a paper copy of this Privacy Policy.

Access right and right to oppose or amend: Any individual has a right of access to all his/her Personal Medical Information and/or other Personal Data that are processed by Virco (unless applicable law prohibits such access), and, as appropriate, has the right to correction or amendment of such data or to erasure or blocking of data not processed in compliance with applicable data protection principles.

Right to accounting of disclosures: Any individual has the right to receive a list of disclosures made of his/her Personal Medical Information and other Personal Data.

Right to cancel further use or processing: Any individual has the right, at any time and without cost, to oppose the further use by Virco of their sample, Personal Medical Information and other Personal Data.

How to exercise your rights

In order to exercise your rights described in this notice you must send a written request to:

Virco BVBA
Attn. Data Privacy Officer
Gen. De Wittelaan L 11B 4
2800 Mechelen
Belgium

Or e-mail to: Privacy-Officer-Virco@its.jnj.com

We request that patients who wish to exercise their rights contact their ordering Medical Professional, who will liaise with Virco on their behalf.

Complaints

If you believe your privacy rights or (if you are a Medical Professional) the privacy rights of one of your patients have been violated, you have the right to report a complaint to the Data Privacy Officer following the procedure as described above.

Virco will take no reprisals or otherwise retaliate against any individual for filing a complaint.

Contact us

If you have any questions, comments, requests, or concerns related to this Privacy Policy, please contact the Virco BVBA Customer Service by:

using the "contact us" form of the Virco BVBA website, or
calling the Customer Service group at + 32 15 286 300, or
e-mail to: virco.customer.service@its.jnj.com
writing to Virco at the following address : Virco BVBA, Attn. Customer Service, Gen. De Wittelaan L 11B 4, 2800 Mechelen, Belgium

Changes to Virco's Privacy Policy

Virco reserves the right to amend this Privacy Policy, at any time. Changes adopted will apply to any sample, Personal Medical Information or other Personal Data we possess about a patient or Medical Professional. Virco is required to comply with the terms of its current Privacy Policy. The Privacy Policy then in effect will be posted on the Virco website www.vircolab.com at all times.

Last updated: 29 Jun 2009 13:51:16