INFORMATION PROCESSING POLICIES

Down Syndrome Corporation

Address: Bogotá DC
Addresses: Cra. 49 # 99 - 10 Castellana PBX 7560475 and Cra. 57 C # 128-03 Villas
Email: direccion@corporacionsindromededown.org

The protection of your data is important to us. In compliance with the provisions of Statutory Law 1581 of 2012 and Unique Decree 1074 of 2015, we inform our Information Treatment Policies which are mandatory in all activities that involve, totally or partially, the collection, storage , the use, circulation, transmission, transfer and deletion of personal data that CORPORACION SINDROME DE DOWN (hereinafter CSD) carries out, by virtue of the authorization granted by you to carry out said treatment.

1. Objectives of the terms and conditions of the treatment policy
of the information.

This document contains our policy for the treatment of information and personal data, and includes what information we collect in the provision of our services and for what purposes, how we use it, when we share it and how we protect it, as well as the rights that assist them. holders of the information and the procedures to exercise them.

2. Information and personal data that we obtain.

To fulfill the purposes indicated in number 3 below, CSD collects, stores, uses, circulates, communicates and transfers personal data with companies that provide health services located in Colombia. Said personal data and information include, among others:

2.1. User Information: In the process of attention and orientation to Families (SAOF) the information of the users is registered, to initiate the connection according to the service or program requested; said information is submitted for registration in FR-02 by CSD. This information includes:

  • Names and surnames of the user and their family nucleus
  • Type and identification number of the user and their guardians or managers
  • Date of birth, age and gender.
  • Contact landlines and / or cell phones, emails, address and place of residence.
  • EPS to which it belongs
  • Health coverage plan (contributory, special or subsidized regime)
  • Socio-economic stratum (if applicable)
  • Name, identification, address, telephone numbers, marital status, age, date of birth of the parents and age of the siblings
  • Company where the user's parents or guardians work, position, educational level

Additionally, the following user information is handled:

  • Copy of identification document
  • Copy of medical examinations, according to monitoring of health conditions
  • Annual plans
  • Periodic progress reports in the different areas of attention. Not only the evolution of the user but also of his family and the actions that are carried out in the different environments (garden, school, university, company) as part of the process of training and therapeutic, pedagogical and occupational intervention are recorded.
  • Socioeconomic evaluation when applicable (confirmation of socioeconomic status, evaluation or follow-up of family or psychosocial risk situations) 
  • When the parents authorize it in FR-229, photos and / or video recording of images handled for therapeutic, pedagogical, job training or community awareness purposes.

2.2. Information from donors and sponsors:

  • Donor's name or company name, identification number or NIT with verification digit, place of residence, address, telephone numbers, fax, email, company purpose
  • In the case of companies, name of the general manager or legal representative and address, landline and cell phone, fax, email. 
  • Name of the person in charge, corporate phone and corporate email or personal email if applicable. 
  • Name of the person assigned to collect the donation, corporate phone and corporate email. The use that the donor wishes his contribution to be used is also recorded.

2.3 Information on suppliers and contractors

  • Name of the supplier or contractor or company name, identification number or NIT with verification digit, place of residence, address, landline and cell phone, fax, email.
  • In the case of companies, name of the general manager or legal representative and address, landline and cell phone, fax, mail
    electronic.
  • Tax and payment information to the general social security system
  • Bank information including name of the bank account holder, bank account number and name or code of the bank
  • Copy of identification document

2.4 Information from APBs, habilitation funders and entities project contractors

  • Company name, identification number or NIT with verification digit, place of residence, address, landline and cell phone number,
    fax, email.
  • Name of the general manager or legal representative and address, landline and cell phone, fax, email.
  • Tax and payment information to the general social security system, when applicable
  • Bank information including name of the bank account holder, bank account number and name or code of the bank 
  • Contracts or established rate agreements, and all related documentation

2.5 Payroll or contracted personnel for the provision of services

  • Company name, identification number or NIT with verification digit, place of residence, address, landline and cell phone number,
    fax, email.
  • Information related to your training and resume, as well as your selection tests and the hiring, training and follow-up process

3. Purpose of the information processing

The personal data that we process is used for the following purposes:

  • Provide the services and programs required by CSD users.
  • Execute the existing contractual relationship between CSD and its contracting health service providers,
    contractors, workers
  • Carry out satisfaction surveys to measure the quality of the service we are providing and establish opportunities for improvement.
  • Inform about new services and / or about changes in them.
  • Respond to requests or claims.
  • Make administrative and quality control reports
  • Contact applicants for admission, donors, employees or suppliers to send information related to the contractual, commercial and mandatory relationship that is necessary.
  • Develop the process of selection, evaluation, and employment relationship.
  • Register the information of active and inactive applicants, users, employees and suppliers in the CSD database.
  • Send information to state and judicial entities, when they require it.
  •  Comply with the legal and regulatory obligations that correspond to you as an employer.
  • Achieve the adequate development of CSD's internal operation and administration activities, such as the administration of its information and communication systems, the generation of files and backup copies of the information contained in the equipment provided to its workers, structuring and implementation of benefit schemes and salary structures, hygiene measures, industrial safety, prevention and care of common and occupational diseases and accidents.
  • Control and prevent fraud and money laundering.
  • Implement security mechanisms and protocols for CSD infrastructure and facilities
  • Carry out epidemiological control

4. Use of information and special treatment of personal data sensitive

CSD uses the information to carry out activities associated with the provision of therapeutic, pedagogical, job training and psychological support services and programs, both in what corresponds to the user himself and his family and surroundings.

It handles sensitive data such as the health status of users, the development process and the achievement of objectives outlined within the processes, evolution data, as well as other sensitive data related to medical and pedagogical history and history.

Additionally, CSD, in compliance with its obligations as an employer, may collect or receive sensitive personal data from its workers, such as data related to their health. Sensitive personal data will be kept and treated with strict security and confidentiality for the purposes related to the provision of health services or compliance with Colombian labor regulations, always bearing in mind that the medical record has a legal reserve in accordance with the provisions of Law 23 of 1981 and Resolution 1995 of 1999 and other applicable regulations.

The information, especially in relation to the user's history, is handled with strict confidentiality. The report is shared with the funding APB after the initial evaluation and the subsequent six-monthly or annual evolution according to the stage of life in which the child or young person is. Internally, only professionals related to customer service have access to the history.

CSD may transfer or transmit, all or part of the personal data of the holders of the information to EPS health service providers, contracting insurance companies, employees, contractors, service providers, suppliers, distributors, consultants and service providers of health located in Colombia solely for the purposes of providing support services, compliance with contracts entered into by the Corporation or for the execution of its corporate purpose, who will be obliged to treat such personal data as responsible for the themselves and in accordance with the purposes and uses provided for in these policies.

5. Protection, security and confidentiality of information.

CSD may keep the personal data of the holders of the information in physical or digitized databases located in Colombia, complying with the purpose authorized by the holder of the data, making its best efforts to keep the information secure, safeguarding its integrity, veracity and confidentiality.

CSD has established information security policies, procedures and standards, the objective of which is to protect and preserve the integrity, confidentiality and availability of information, regardless of the medium or format where it is located, its temporary or permanent location or the way it is that it be transmitted.

In this sense, we rely on technological security tools and implement recognized security practices in the industry, which include: use of secure protocols; assurance of technological components, restriction of access to information only to authorized personnel, information backup, secure software development practices, among others.

The third parties hired by CSD are also obliged to adhere to and comply with the information security policies and manuals, as well as the security protocols that we apply to all our processes.

Every CSD contract with third parties (contractors, external consultants, temporary collaborators, etc.) that involves the treatment of information and personal data, includes a confidentiality agreement that details its commitments for the protection, care, security and preservation of confidentiality, integrity and privacy of it.

The server where the information is stored may be in Colombia or abroad.

6. Rights of the holders

Because it is sensitive data, users and / or workers have the power to answer questions about this type of data and are not obliged to authorize its treatment. Regarding sensitive data, CSD guarantees special care and responsibility in their treatment and has implemented security parameters.

CSD undertakes to respect and guarantee the following rights of the data subjects:

  • Know, update and rectify your personal data, a right that may be exercised, among others, against partial data,
    inaccurate, incomplete, fractioned, misleading or those whose treatment is expressly prohibited or has not been authorized.
  • Obtain a copy of the authorization given for the treatment of the data.
  • Know the use that has been given to your personal data.
  • Present before the Superintendence of Industry and Commerce complaints for infractions to the provisions of Statutory Law 1581 of 2012, Single Decree 1074 of 2015 and other regulations that modify, add or complete them.
  • Revoke the authorization and / or request the deletion of the data when the principles, rights and
    constitutional and legal guarantees. The revocation and / or deletion will proceed when the Superintendency of Industry and Commerce has determined that in the Treatment the Responsible or Person in Charge have engaged in conduct contrary to the law and the Constitution.
  • Access your personal data for free. The information requested by the owner may be provided by
    any means, including electronic ones, as required by the owner.
  • In the case of sensitive data, the owner has the right not to grant his authorization for the treatment. It is clarified that the holders will not be able to revoke the authorization and request the deletion of the data, when there is a legal or contractual duty that imposes the duty to remain in the database or file of the Responsible or Person in Charge.

7. Procedure so that the holders can exercise their rights to know, update, rectify and delete information and revoke authorization.

The area responsible for the attention of requests, queries and claims before which the holders can exercise their rights is the Administrative area.

To make their rights effective, the owners can send their request to the email assistant@corporacionsindromededown.org, or file it at any of the venues. There are also suggestion boxes at the receptions of both headquarters and complaints and claims are sent to the CSD Directorate, who together with the person responsible for the process involved in the complaint, will establish whether there was any failure on the part of CSD in the management of the information and will take the pertinent corrective action, informing the user or the person or entity complaining about it.

In accordance with the provisions of article 16 of Law 1581 of 2012, the owner or interested party may only file a complaint with the Superintendency of Industry and Commerce once the consultation or claim process with the CSD has been exhausted.

8. Modifications to the Security Policy

CSD reserves the right to make modifications or updates to this Privacy Policy at any time, in order to attend to new legislation, internal policies or new requirements for the provision of services. Said modifications will be published on our website before their implementation.

9. Validity

This General Information Management Policy is effective from the date of its publication (November 13, 2018) and may have periodic updates. Last update June 5, 2020. 

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