Last update: May 5, 2023
The purpose of this policy is to protect the privacy of individuals who have sensitive information stored (either in electronic or paper form) on assets either owned or used by Kirklin Solutions, while at the same time providing the ability to share this information with authorized entities as required by legitimate business need or by law.
Limits on the Use of and Access to Sensitive Information
The responsible use of sensitive information requires that Kirklin Solutions respect individual privacy, protect against unauthorized access to or use of information, and comply fully with all laws and government regulations in the collection, use, storage, display, distribution, and disposal of such information. Authorized uses of sensitive information within Kirklin Solutions are limited to uses that
Access to sensitive information is limited to:
Online Collection of Information
California Consumer Privacy Act (CCPA)
The California Consumer Privacy Act of 2018 (CCPA) gives consumers more control over the personal information that businesses collect about them and the CCPA regulations provide guidance on how to implement the law. This landmark law secures new privacy rights for California consumers, including:
European Union General Data Protection Regulation (EU GDPR) Privacy Notice
Lawful Basis for Collecting and Processing of Personal Data
Kirklin Solutions is involved in education, research, and community development. For Kirklin Solutions to educate, engage in world-class research, and provide community services, it is essential, and necessary, and Kirklin Solutions has lawful bases to collect, process, use, and maintain data of its employees, applicants, research subjects, and others involved in its educational, research, and community programs. The lawful bases include, without limitation, communications, research, development, program analysis for improvements, and records retention. Examples of data that Kirklin Solutions may need to collect in connection with the lawful bases are name, address, IP address, physical address or other location identifier, photos, as well as some sensitive personal data obtained with prior consent.
For more information regarding the EU GDPR, please review the European Union General Data Protection Regulation.
Most of the collection and processing of personal data will fall under the following categories:
Types of Personal Data collected and why
Kirklin Solutions collects a variety of personal and sensitive data to meet one of its lawful bases, as referenced above. Most often the data is used for the provision of medical services, participation in research, development, and community outreach. Data may typically include name, address, research subject information, and medical and health information. If you have specific questions regarding the collection and use of your personal data, please contact the Office of Information Security.
If a data subject refuses to provide personal data that is required by Kirklin Solutions in connection with one of the lawful bases to collect such personal data, such refusal may make it impossible for Kirklin Solutions to provide research or other requested services.
Kirklin Solutions gets Personal and Sensitive Personal Data
Kirklin Solutions may receive personal and sensitive data from multiple sources. Most often, Kirklin Solutions gets this data directly from information entered by authorized external data entry entities which enter the data under the approval of the data subject who has provided it to a third party.
Individual Rights of the Data Subject under the EU GDPR
Individual data subjects whose information is collected under the Kirklin Solutions’ European Union General Data Protection Regulation Compliance Policy will be provided the following information at the time the information is collected from them:
Individual data subjects whose information is collected under the GDPR will be provided the following rights (as applicable), provided that Kirklin Solutions determines that the exercise of the right is permitted and/or required by the GDPR:
Any data subject who wishes to exercise any of the above-mentioned rights may do so by filling such request.
Cookies are files that many websites transfer to users’ web browsers to enable the site to deliver personalized services or to provide persistent authentication. The information contained in a cookie typically includes information collected automatically by the web server and/or information provided voluntarily by the user. Our website uses persistent cookies in conjunction with a third-party technology partner to analyze search engine usage and web traffic patterns. This information is used in the aggregate to monitor and enhance our web pages. It is not used to track the usage patterns of individual users.
Security of Personal Data subject to the EU GDPR
All personal data and sensitive data collected or processed by Kirklin Solutions under the scope of the European Union General Data Protection Regulation Compliance Policy must comply with the security controls and systems and process requirements and standards set forth in the University’s Data Classification and Protection Standard.
We will not share your information with third parties except:
Kirklin Solutions keeps the data it collects for the time periods as needed or required by international, federal, and state laws.
CCPA - The California Consumer Privacy Act of 2018 (CCPA) gives consumers more control over the personal information that businesses collect about them and the CCPA regulations provide guidance on how to implement the law.
GDPR - The General Data Protection Regulation (GDPR) is a legal framework that sets guidelines for the collection and processing of personal information from individuals who live in the European Union (EU).
PERSONNEL / RESPONSIBILITIES
All employees are responsible for implementing, reviewing, and monitoring internal policies, practices, etc. to assure compliance with this policy.
Consequences and Sanctions
Violation of this policy may incur the same types of disciplinary measures and consequences as violations of other Kirklin Solutions policies, including up to and including termination of employment.