ANCHOR HMO INTERNATIONAL COMPANY LIMITED
Data Privacy Policy
Welcome to Anchor HMO International
Company Limited (“Anchor HMO”) privacy policy. We appreciate you taking the
time to read all our notices carefully. Anchor HMO is committed to protecting
your privacy by ensuring that any personal data collected is used lawfully and
transparently.
This privacy policy explains how
personal data is collected and used when you use our website. It also explains
how we process any data that you supply to us on this website, for instance to
request a quote or to use our online services.
This Privacy
Notice explains:
·
Who
we are
·
Personal
data we collect
·
Our
legal basis for processing
·
Who
we may share information with and why
·
Where
we may transfer data to
·
How
we keep information secure and deal with security incidents
·
How
long we may keep your data for
·
Your
data privacy rights
·
How
to contact our DPO and the Data Controller
Who
is Anchor HMO?
ANCHOR HMO INTERNATIONAL COMPANY
LIMITED is a Health Maintenance Organisation (HMO) incorporated in Nigeria to
carry out the business of providing easy access to quality health services for
individuals and corporate entities. A member of the Anchor Insurance Group, we
have an authorized share capital in excess of 500 million naira in accordance
with the provision of decree 35 of the Federal Government of Nigeria, which
established the National Health Insurance Scheme.
We have designed several health
plans to meet the needs of all the segments of the society. Our health care
plans are specially designed to meet the demands of large and small employers
alike. We believe in equality, excellence, unrivalled customer services alongside
innovative care delivery, and all of these together have been responsible for
our uniqueness in the managed healthcare industry. As a Health Maintenance
Organization, we have contracts with over 900 clinics/hospitals nationwide. Our
network of hospitals and clinics are geographically spread over 126 Nigeria
cities in all states, we also run and manage out sourced worksite clinics and
health centres nationwide.
Anchor HMO recognize
the importance of client’s privacy and the need to securely hold personal
information relating to them. This
Privacy Policy explains what information we collect, how we collect, share,
use, and protect your personal information when you visit or use our web site
and other services offered by Anchor HMO. You are also informed of your rights
regarding the information we process and how you can contact us. By continuing
to visit our websites (www.anchorhmo.com) and other Anchor HMO customer touchpoints,
you accept and consent to the practices described in this policy
Purpose Of This Policy
This Policy sets out
how Anchor HMO will process the personal data of its customers, staffs, suppliers
and other third parties.
This Policy applies to
all personal data that the company processes regardless of the format or media
on which the data are stored or who it relates to.
Scope Of the Policy
This policy applies to
all parties – Employees of the company and its subsidiaries and other
stakeholders who may provide information to the Company such clients / customers
and are expected to follow the policy along with any entity the Company
collaborates with or such entity that Acts on behalf of the Company who may
have need of the data we have.
Personal
Data
Personal data is defined under the Nigerian Data Protection and
Compliance Regulations (NDPR) as: “Any information relating to an identified or
identifiable natural person ('data subject'); an identifiable natural person is
one who can be identified, directly or indirectly, in particular by reference
to an identifier such as a name, an identification number, location data, an
online identifier or to one or more factors specific to the physical, physiological,
genetic, mental, economic, cultural or social identity of that natural person”.
The Data We Collect
Personal information refers to data that could identify a specific
individual such as names, addresses, e-mail addresses, and telephone numbers.
We collect information about you from various sources such as websites visits,
applications, identification documents, personal financial statements,
interactions with our relationship management officers, and other third parties
(credit bureaus, payment gateways etc.) and other written or electronic
communications. Depending on your medium of interaction with Anchor HMO, we
collect various types of information from you, as described below.
·
Personal details (e. g. name, date of
birth, passport information or other identification information)
·
Contact details (e. g. phone number,
email address, postal address or mobile number);
·
Transactional details (e. g. payments you
make and receive)
·
Biometric information (e. g. fingerprints,
facial recognition, or voice recognition)
·
Financial information (e. g. bank account
number, debit card numbers, financial history) including information you
provide to deliver payment initiation services and account information services
regarding accounts you hold with other providers
·
Education and employment
information.
·
Information about your
family, lifestyle
and social circumstances (such as dependents, marital status, next of kin and
contact details);
·
Information about any other Anchor HMO products and services you
currently have, you have applied for, or you have previously held.
·
Visual images and personal appearance
(such as copies of passports or CCTV images
·
Online profile and
social media information and activity, based on your interaction with us and our websites and applications,
including for example your banking profile and login information, Internet
Protocol (IP) address, smart device information, location coordinates, online
and mobile banking security authentication, mobile phone network information,
searches, and site visits.
HOW
WE COLLECT YOUR INFORMATION
We collect personal information from
different sources. Most of the data we collect will come from you, for example
when you:
·
enquire
about our activities, our services, or ask us a question;
·
provide
your contact details to us when registering to use or accessing any websites or
portals we make available or when you update those details;
·
request
marketing material to be sent to you;
·
e-mail
or get in contact with us in some way;
·
voluntarily
complete a customer survey or provide feedback on any of our message boards or
via email or participate in any other interactive areas that appear on our
website or portals;
·
use
or view our website via your browser’s cookies;
·
interact
with us using social media;
·
contact
us offline, for example by telephone, SMS, e-mail, post or any other means of
communication;
·
partially
complete and/or abandon any information inputted into our website and/or other
online forms and may use this information to contact you to remind you to
complete any outstanding information.
In addition, as you interact with
our website, we will automatically collect technical data about your equipment,
browsing actions and patterns. We collect this personal data by using cookies,
server logs, and other similar technologies
HOW WE USE YOUR PERSONAL DATA
To the extent permissible under applicable law, we may use your
information for the following legitimate actions:
·
to provide you with access to our
Health Insurance Policies;
·
Providing and operating the products and services you have
requested
·
For other related purposes which may include updating and
enhancing Anchor HMO records, understanding your financial needs, conducting
credit checks, reviewing credit worthiness, and assisting other financial
institutions to conduct credit checks
·
Identifying and informing you about other products or services
that we think may be of interest to you
·
For crime/fraud prevention and debt collection purpose
·
To plan, conduct and monitor Anchor HMO’s business
·
For improving the design and marketing of our range of services
and related products for customer use.
·
Compare information for accuracy and to verify it with third
parties/publicly available information.
·
Manage our relationships with you
·
To monitor, carry out statistical analysis and benchmarking to
identify potential markets and trends, evaluate and improve our business
·
Monitor activities at our facilities, including compliance with
applicable policies
·
For purposes required by law or regulation Without your personal
information, we may not be able to provide or continue to provide you with the
products or services that you need.
With whom may Anchor HMO share Personal Data?
As a general rule, Anchor HMO does not and will not share
Personal Data with third parties except as necessary for the proper execution
of processes related to the provision of health care, or the use or disclosure
is reasonably necessary, required or authorized by or under law.
When we share your Personal Data with third parties, we
require those third parties to enter into a Third-Party Data Processing
Contract with us that requires them to use the Personal Data we transfer to
them in a manner that is consistent with this Privacy Notice and applicable
laws.
The following are
examples of how we may disclose information.
We share information:
·
With trusted businesses or persons
for the purpose of processing personal information on your behalf. We require
that these parties agree to process such information based on our instructions
and in compliance with the General Data Protection Regulation (GDPR) and the
Nigerian Data Protection Regulation (NDPR) and any other appropriate
confidentiality and security measures.
·
To satisfy any applicable law,
regulation, legal process or enforceable governmental request.
·
To enforce applicable Terms of
Service, including investigation of potential violations thereof.
Our Legal Basis for Processing
Before processing any personal data,
we ensure that at least one lawful basis under NDPR is met. We will not
disclose personal data for any purpose other than what the data was originally
collected for; unless there is an overriding legal basis that enables this
processing. Anchor HMO personnel or any third party
acting on its behalf shall only process your personal data if at least one of
these conditions are met:
·
Consent: this refers to any
freely given, specific, informed, and unambiguous indication through a
statement or a clear affirmative action that signifies your agreement to the
processing of your Personal Data by Anchor HMO. Anchor HMO shall not seek
consent that may engender direct or indirect propagation of atrocities, hate,
criminal acts, and anti-social conducts.
·
Contract: processing is necessary
for the performance of a contract or entering a contract at your request.
·
Legal obligation: processing is necessary
for compliance with a legal obligation to which Anchor HMO is subject.
·
Vital interest: processing is necessary
to protect your vital interests or those of another natural person.
·
Public interest: processing is necessary
for the performance of a task carried out in the public interest or in the
exercise of official authority vested in Anchor HMO.
·
Vendors, Consultants and Third-party Service
Providers: processing is required
for legitimate interests of Anchor HMO or a third party insofar as this does
not conflict with the requirements for the protection of your personal data.
How We Protect Personal Data
Anchor HMO strictly
enforces its Privacy Notice. It has implemented technical, organisational and
physical security measures to protect Personal Data from loss, misuse, unauthorized
modification, unauthorized or accidental access or disclosure, alteration or
destruction. Anchor HMO uses safeguards such as the following:
·
Use of secured servers and
firewalls,
·
Encryption on computing devices;
·
Restricted access only for qualified
and authorized personnel; and
·
Strict implementation of information
security policies.
Storage of Personal Data
Anchor HMO stores Personal Data in both local and remote
facilities, such as data centre (on premises and cloud) and physical document
storage facilities. Records will only be kept for such time as the individual
or juristic entity has a relationship with Anchor HMO or as required by law or
to support a business need, following which they will be archived or securely
disposed of.
Transfer of Personal
Data
Personal data collected by Anchor HMO may be transferred among its
various divisions (with personnel who have business need to know). Other than
to those individuals and entities listed below, your details will not be revealed
by Anchor HMO to any external body unless Anchor HMO has your permission or is
under either a legal obligation or any other duty to do so. For the purposes
detailed above, your information may be disclosed to:
·
Other Branches in Anchor HMO
·
Any regulatory, supervisory, governmental, or quasi-governmental
authority with jurisdiction over Anchor HMO
·
Any agent, contractor or third-party service provider,
professional adviser, or any other person under a duty of confidentiality to Anchor
HMO.
·
Credit
reference agencies and, in the event of default, dept collection agencies.
·
Any actual or potential participant or sub-participant in,
assignee, novate or transferee of, ant of the Anchor HMO rights and/or
obligations in relation to you.
·
Any financial institution with which Anchor HMO has or proposes to
have dealings.
·
If we
intend to transfer the personal data to a third party or international
organization, we ensure this is done securely. The Honorable Attorney General
of the Federation (HAGF) will approve sending personal data to some countries
because they require a minimum standard of data protection. In other cases, we
shall ensure that there are specific measures in place to secure your
information.
Retention of Personal Data
Information held about you is retained if the purpose for which
the information was collected continues. The information is then destroyed
unless its retention is required to satisfy legal, regulatory, or accounting
requirements or to protect Anchor HMO’s interest. Please note that regulations
may require the Anchor to retain your personal data for a specified period even
after the end of your business relationship with us. It is your responsibility
to maintain the secrecy of any user ID and login password you hold.
Your
Data Privacy Rights
All data subjects have
individual rights. On a case-by-case basis, you have the following rights in
relation to your personal data processed by Anchor HMO:
·
The right to be informed – To emphasize the need
for transparency over the usage of personal data, we ensure fair processing of
information typically through this privacy policy.
·
The rights to access – You have the right to
request from Anchor HMO for copies of your personal data where those requests are
reasonable and permitted by law or regulation. We may charge you a small fee
for this service.
·
The right to rectification – You have the right to request that Anchor HMO
correct any information you believe is inaccurate. You also have the right to
request Anchor HMO. to complete information
you believe is incomplete.
·
The right to restrict
processing –
You have a right to ‘block’ or withdraw your consent to our processing of your
information, which you can do at any time. When processing is restricted, we
are permitted to store the personal data, but not further process it.
·
The right to erasure – You have the right to request the deletion or removal of
personal data where there is no compelling legal or regulatory requirement for
its continued processing. Anchor
HMO will make sure that this right is protected.
·
The right to data
portability – You have the right to request that the
bank transfer the data that we have collected to another organization, or
directly to you, under certain conditions. We will ensure that personal data is
moved, copied, or transferred easily from one IT environment to another in a
safe and secure way, without hindrance to usability.
·
The right to object – You have the right to object to our processing of your
information if there are compelling legitimate grounds to do so and to the extent
permitted by law or regulation. To exercise your right(s), please contact the
Data Protection Office of Anchor
HMO.
You also have the right to:
·
The right to receive your Personal Data in a commonly used and machine-readable
format and the right to transmit these data to another Data Controller when the
processing is based on (explicit) consent or when the processing is necessary
for the performance of a contract.
·
The right to lodge a complaint with the National IT Development
Agency (NITDA) where you believe our processing of your data violates the
requirements of the Nigeria Data Protection Regulation 2019 (NDPR).
You may exercise any of the above
rights by emailing our Data Protection Officer at olowoake.i@anchorhmo.com.
Please note that in some cases we may not be able to comply with your request
for reasons such as our own obligations to comply with other legal or regulatory
requirements. We will always respond to any request you make and if we can’t
comply with your request, we will inform you of the reasons why.
Queries
and Complaints
You can contact us at any time. Should you have any
enquiries, feedback, and/or complaints, you may reach the Data Protection
Officer (DPO) through the following contact details:
Mr. Idrees Olowoake,
Anchor HMO International Company Ltd,
Goldcrest Plaza, Km 23 Lekki – Ajah Expressway,
Ikota First Gate, Lekki, Lagos, Nigeria.
Tel: +2348181803779.
E-mail: olowoake.i@anchorhmo.com
Privacy Policy Update
Anchor HMO reserves the right to amend its prevailing Data
Protection and Privacy Statement at any time and will place any such amendments
on our websites (www.acnhorhmo.com). The latest version of our privacy
statement will replace all earlier versions unless it says differently. Please
check back frequently to see any updates or changes to our Notice. This policy
is not intended to, nor does it, create any contractual rights whatsoever or
any other legal rights, nor does it create any obligations on Anchor HMO in
respect of any other party or on behalf of any party.