Collection, Use and Security of Personal Information
A. RJMedical Collection of Personal Information
1. The RJMEDICAL will collect Personal Information on an individual only if the individual provides the information to the RJMEDICAL. The RJMEDICAL also may collect information about a person who has been referred to the website to send them emails regarding RJMEDICAL’s efforts or a person to whom the RJMEDICAL has been asked to send emails regarding RJMEDICAL’s programs or efforts. If a person donates to the RJMEDICAL, the RJMEDICAL may collect sensitive Personal Information such as the donor’s credit card number, card type, expiration date and keep a record of the financial transaction.
RJMEDICAL may collect Demographic Information it obtains from individuals and third parties for fund raising purposes and to notify persons of RJMEDICAL programs, events, educational opportunities and upcoming meetings.
RJMEDICAL may collect Aggregate and Transactional Information and add to its database every time a person visits an RJMEDICAL Web Site. Also, the RJMEDICAL collects Aggregate Information for research purposes.
2. Types of information: "Personal Information" is "Demographic Information" and/or "Medical Information" which identifies a specific individual with a minimal degree of effort. Demographic Information includes name, address, city and other similar information. Medical Information includes diseases, treatments, lifestyle behaviors, family history, genotype, phenotype and other similar information. Transactional Information is data collected on an individual based on the individuals' interactions with the RJMEDICAL, which may include sensitive information such as credit card information and Medical Information. Aggregate Information is information presented in summary or statistical form which does not contain data that would permit the identification of a specific individual without extraordinary effort.
B. RJMEDICAL Use of Personal Information
1. When an individual provides Personal Information to the RJMEDICAL, we may use the Personal Information for its programs, research and fund raising with Individual approval only.
2.RJMEDICAL uses Transactional Information for research purposes for the development or implementation of its programs, products and services. The presumption is that, since Transactional Information is highly proprietary, it will not be disclosed to third parties.
3. RJMEDICAL will disclose all information as required by law.
4. RJMEDICAL will make every effort to discontinue the use of an individual's Personal Information as soon as practicable if requested by that individual. RJMEDICAL may need to retain Information in its archives and records to comply with law, resolve disputes, analyze problems, assist with any investigations, enforce RJMEDICAL’s User Agreement and other policies, and take other actions otherwise permitted or required by law.
C. Specific Requirements
a.RJMEDICAL will take reasonable and appropriate measures to keep Personal Information confidential and in a secure environment, including taking appropriate action in the event of unauthorized disclosure.
b. Access to Personal Information will be restricted to only those personnel with a legitimate business purpose.
c.RJMEDICAL owns all Personal Information provided to it by individuals and collected in accordance with this Policy. When an individual provides Medical Information to the RJMEDICAL, we will ensure that the individual acknowledges their assignment of the right to use the data to the RJMEDICAL.
2. Scientific Research
Any research funded by the RJMEDICAL that involves human subjects (e.g., information collected on individuals) must be endorsed by the sponsoring institution's committee on clinical investigation or other appropriate body, and conform ethically to the guidelines prescribed by the National Institutes of Health, which includes obtaining informed consent from each individual.
3.Third Party Disclosure
Permission is required before RJMEDICAL discloses Personal Information to a third party. No permission is necessary for Aggregate Information, since Aggregate Information does not identify a specific individual.
a. For disclosure of Demographic Information (e.g., rentals or exchanges of donor lists),RJMEDICAL as a minimum will use the "Opt Out" approach. An "opt-out" is obtained when RJMEDICAL through some correspondence gives an individual the opportunity to decline or "opt-out" of disclosures to third parties. If the individual does not opt out, permission is deemed granted. Depending upon the nature of an activity or project, a higher standard than "opt-out" may be used, such as "opt-in" whereby an individual must affirmatively give consent before information is disclosed.
b. For research awardees, permission is deemed granted upon submission of an application for a grant to RJMEDICAL. Therefore, the RJMEDICAL may disclose Personal Information, including funding and project summary information, on research program awardees to third parties.
c. For disclosure of Medical Information, Informed Consent is required before the RJMEDICAL discloses Medical Information to a third party. Informed Consent occurs when an individual has sufficient facts about the disclosure, comprehends those facts, and voluntarily consents to the disclosure. Where a third party such as the employer or healthcare provider of an individual requires the individual to participate in an RJMEDICAL program which collects Medical Information, the RJMEDICAL will require the employer or healthcare provider to procure Informed Consent before the RJMEDICAL will release Medical Information to that employer or healthcare provider.
d. From time to time, there is a benefit in allowing a third party to use collected Personal Information on individuals. However, unless an individual gives permission, the RJMEDICAL will not disclose Personal Information collected by the RJMEDICAL to any third party. The RJMEDICAL sometimes engages third parties to provide certain operational services to the RJMEDICAL or on its behalf. The RJMEDICAL may disclose Personal Information to those third parties on a “need to know” basis under a written contract.
e. RJMEDICAL uses and allows third parties to use Aggregate Information for research purposes for the development or implementation of its programs, products and services.