Privacy Statement
PLEASE READ THIS PRIVACY NOTICE CAREFULLY.
This Privacy Notice (“notice” or “privacy notice”) describes how Medtronic collects and uses information about you (“identity information”) in connection with the activities described below. Unless set out otherwise below, the Medtronic company responsible for processing your identity information is Medtronic Bangladesh Private Limited.
In this privacy notice, we’ll tell you what identity information we obtain about you, how we use that information, with whom we share it, what rights you have regarding your information, and how to contact us to exercise these rights.
This privacy notice does not apply when you have been notified that an alternative notice applies (for example on other Medtronic websites) or where Medtronic processes your identity information on behalf of your medical institution or healthcare professional in connection with your medical treatment. Your medical institution and/or healthcare professional is solely responsible for the processing of your identity information for the provision of your medical treatment and care.
This notice does not apply to data processing activities specifically relating to current or former Medtronic employees or applicants – the relevant notice may be requested by contacting AskHR@Medtronic.com.
Broadly, “Identity Information” means such information which consists of information relating to any external, biological, physical, electronic and/or digital information or any other information which singly or jointly can identify a person or a system, their name, address, date of birth, mother’s name, father’s name, signature, National Identity Number, birth and death registration number, finger print, passport number, bank account number, driver’s license, E-TIN number, electronic or digital signature , username, credit or debit card number, voice print, retina image , iris image , DNA profile, security related questions or any other identification.
Individual’s Identity Information does not include any information which is furnished under the Right to Information Act, 2009 or any other law for the time being in force.
2. Collection
Medtronic collects individual’s Identity Information that is reasonably necessary for or directly related to our functions and activities as a provider of medical devices with your written or electronic/digital consent. In some cases, we are required to collect individual’s Identity Information in order to comply with our obligations such as responding to safety concerns about our products.
Medtronic may collect Identity Information about you through our interactions with you. Where Medtronic collects Identity Information from or about you, we may inform you about the purpose and use of the collected information, the intended recipients of such information and if it is collected or transferred by/ to third parties the name and address of such third party collecting and retaining the information.
If you are a patient, additional Identity Information we may collect includes:
▪ Details of your health care professional; ▪ Your implantation details and history; ▪ Product performance, service and reliability data; ▪ Product data, such as model and usage of your device; ▪ Credit related information, if applicable.
Individual’s Identity Information may be collected by Medtronic in the course of:
▪ If you are a patient or healthcare professional, providing technical assistance about our products or services; ▪ Responding to product complaints; and ▪ Participation in Medtronic sponsored programs, including educational programs and research grants.
Medtronic will, prior to collection of your Identity Information, provide you an option to not provide the information sought to be collected. You will also have an option to withdraw your consent (to be expressed in writing), which you may have earlier granted to Medtronic.
3. Use and disclosure
Medtronic may collect and use your Identity Information, with your written or electronic/digital consent, for the purpose for which it is collected, which inter alia may include the following:
▪ In the course of the sale, distribution or provision of medical devices that have been requested by health care providers; ▪ In the course of supporting healthcare professional in ongoing care, if you are a patient; ▪ Administering training programs, clinical trials or other similar programs in which you agree to be involved; and ▪ Compliance with regulatory requirements, such as maintaining a record of medical queries, complaints, adverse events and recalls relating to our products.
We may also use your Identity Information to:
▪ Provide healthcare providers with updated product or safety information with respect to Medtronic medical devices; ▪ Send healthcare providers materials on our activities and products or developments in medical technology that Medtronic believes may be of interest to them; ▪ Manage, plan and arrange meetings between the healthcare provider and Medtronic representatives; and ▪ Generate customer lists for the purposes of market research.
When dealing with individual’s Identity Information, such as your health information, Medtronic may seek your written or electronic/digital consent before using such Identity Information. In only such circumstances where required by law to disclose information or in the event where the Government of Bangladesh has requested such information for the purpose of verification of identity or for prevention, detection, and investigation of cyber incidents and the like, will we disclose your health information without your consent.
4. Cross border data transfer
In some cases, Medtronic may transmit, or store identity information collected with affiliates, vendors, or sites in other countries. We will only transfer identity information as allowed by applicable law to further the purposes set out in this document. Where identity information is transferred to another country, we take administrative and technical measures to ensure adequate safeguards and protections are applied as provided for by applicable law. In cases where identity information is transmitted to other countries, we will ensure that safeguards equivalent to those required by applicable laws are in place.
5. Transfer of data to third parties
Medtronic will not sell or publish your Identity Information to any third party for any purpose. However, Medtronic reserves the right to share your Identity Information for the purposes and in the manner mentioned in Paragraph 3 hereinabove. In the event your Identity Information is required to be transferred to third parties, such transfer will happen only when such third parties have ensured that reasonable security procedures are in place for protection of such Identity Information.
All such third parties are required by Medtronic to process the individual’s Identity Information disclosed to them only for the purposes expressly authorized by Medtronic and are required by Medtronic to meet our standards of data protection and comply with the safeguards under Bangladesh Privacy Laws.
6. Data security
Medtronic has put in place reasonable security procedures and safeguards to protect individual’s Identity Information we hold from misuse, loss, unauthorized access, modification or disclosure. Medtronic holds the Identity Information you provide to us in an electronic form on computer servers, which are password protected for limited access and are located in controlled facilities. However, Medtronic may also hold Identity Information in physical form, such as in paper hard copies. While Medtronic cannot guarantee against any loss, misuse or alteration to data, we take reasonable steps to prevent such occurrences.
Access to the individual’s Identity Information is restricted to those employees who need to use the data, who have been trained to handle such data properly and observe strict standards of confidentiality.
Medtronic destroys or permanently de-identifies individual’s Identity Information that we no longer need, where permitted.
7. Access, correction, and complaints
You have the right, in most cases, depending on applicable laws, to access your Identity Information at any time. Medtronic takes reasonable steps to ensure that any information we hold about you is up-to-date, accurate and complete. If you wish to access or correct Identity Information we hold, or you have any questions about this Notice, please contact Medtronic’s Privacy Officer at rs.askdpo@medtronic.com, setting out a full description of the request.
If you have a complaint about how we have handled your Identity Information or consider that we may have breached our obligations under the Bangladesh Privacy Laws, please write to our Privacy Officer at rs.askdpo@medtronic.com or at:
Medtronic Bangladesh Private Limited
#603, Level 6, Shanta Western Tower, 186 Bir Uttam Mir Shawkat Road, Tejgaon Industrial Area, Dhaka -1208
Email: rs.askdpo@medtronic.com
We will respond to your complain within a reasonable period, usually within 30 working days.
8. Retention of your identity information
Medtronic will retain your Identity Information for no longer than it is required for the purposes for which the information may lawfully be used or is otherwise required under any law in force. In many cases individual’s Identity Information must be kept for considerable periods of time in order to make it available as and when questions or disputes arise. Retention periods will be determined for each information that is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable opportunity.
Medtronic will continue to treat your Identity Information in accordance with this Privacy Notice so long as they retain it.
9. Updating our Privacy Notice
Medtronic may review or revise this Privacy Notice and the way we handle individual’s Identity Information from time to time. Such changes will be consistent with the current privacy legislation in Bangladesh. You may request a copy of our Privacy Notice at any time.
This Privacy Statement was last updated on 11 Dec 2024.