Website Privacy Notice

1. Purpose and status of this notice

University of Ghana Medical Centre Limited ("UGMC", "we", "us" or "our") is committed to protecting the privacy, dignity and confidentiality of people whose personal data we process. This Website Privacy Notice explains how UGMC collects, uses, stores, shares and protects personal data when people use our websites, online forms and connected digital services.

This notice is intended for patients, prospective patients, visitors, carers, parents and guardians, emergency contacts, job and internship applicants, referees, research participants, donors, suppliers, healthcare professionals and any other person who interacts with UGMC through an in-scope digital service.

This notice is a public transparency document. It does not replace professional duties of patient confidentiality, research-consent documentation, employment privacy notices, statutory records obligations or more specific notices supplied at the point of collection. Where a more specific notice applies, it should be read together with this notice.

2. Who we are and how to contact us

For the processing described in this notice, University of Ghana Medical Centre Limited generally acts as the data controller because it determines why and how personal data is processed. In some collaborative research, clinical or administrative arrangements, UGMC may act jointly with another organisation or process information on another organisation's behalf. Any material difference will be explained in the relevant specific notice or agreement.

Privacy enquiries and requests should be addressed to the Data Protection Supervisor using the details above. Please do not include unnecessary medical information in ordinary email correspondence.

3. Scope

This notice applies to personal data processed through digital services managed or operated by or for UGMC, including:

• www.ugmedicalcentre.org and any subdomains controlled by UGMC;
• www.ugmedicalcenter.org, www.ugmedicalcenter.com and www.ugmedicalcentre.com, where these redirect to or support the principal website;
• online appointment, pre-registration, contact, complaint, incident-reporting, payment, donation, recruitment, internship, training, newsletter and research forms;
• website live-chat, messaging and support functions;
• UGMC mobile applications, portals or connected digital services that link to this notice; and
• technical systems that support these services, including hosting, security, email, SMS, analytics and backup services.

This notice does not automatically apply to an external website merely because UGMC links to it. External operators should provide their own privacy information.

4. Data-protection principles

UGMC will process personal data in accordance with the principles established under the Data Protection Act, 2012 (Act 843). In practical terms, UGMC aims to:

5. Personal data we collect

The information collected depends on the service used. UGMC may process the following categories:

6. How we collect personal data

UGMC may collect personal data:

• directly from you when you complete a form, book an appointment, pre-register, communicate with us, apply for a position, subscribe, make a payment or use live chat;
• from a parent, guardian, carer, emergency contact, authorised representative or healthcare professional acting for you;
• from referees, educational institutions, professional bodies or previous employers where permitted and relevant to an application;
• automatically through server logs, cookies, security tools and similar technologies when you use an in-scope service;
• from another UGMC department or system where the transfer is necessary and compatible with the original purpose; and
• from public authorities, insurers, partner institutions, research collaborators or other organisations where the collection is lawful and you have been appropriately informed.

When you provide personal data about another person, such as an emergency contact or referee, you should ensure that person knows their information has been provided to UGMC. UGMC will provide additional information to that person where required and reasonably practicable.

7. Why we process personal data and our lawful grounds

UGMC processes personal data only where a lawful justification applies. The appropriate ground depends on the purpose, relationship and information involved. Consent is not the sole basis for healthcare administration or other processing that UGMC must undertake to provide a requested service or meet a legal duty.

Where UGMC relies on consent, the request will be clear, specific and separate from unrelated conditions. You may withdraw consent, but withdrawal does not invalidate processing already carried out and does not prevent UGMC from continuing processing supported by another lawful ground.

8. Health information and other special personal data

Health information, religious beliefs and certain other categories are special personal data and require heightened protection. UGMC will process such information only where the processing is necessary, proportionate and permitted by law, including where it is required for medical purposes and undertaken by authorised professionals subject to confidentiality obligations.

Access to special personal data is restricted according to role and need. Information collected for pre-registration or a website enquiry does not automatically become available to every member of staff. UGMC records which functions require each sensitive field and removes or makes optional any field that cannot be justified.

A typed name confirming that a form is accurate is not, by itself, consent to every possible use of the information. Optional marketing, research or other distinct processing uses separate, unticked choices where consent is the appropriate basis.

9. Children, patients requiring assistance and representatives

UGMC may process information about children or people who need assistance to use a digital service. A parent, guardian, carer or authorised representative should provide information only where they have appropriate authority or where an emergency, safeguarding or healthcare justification applies.

UGMC may take reasonable steps to verify identity, relationship and authority. A representative's access to information may be limited where this is necessary to protect the patient's confidentiality, safety, capacity, best interests or legal rights.

Digital forms intended for children use clear, age-appropriate explanations. Where a child is able to understand the processing, UGMC involves the child appropriately while also obtaining any required parental or guardian authority.

10. Cookies and similar technologies

UGMC websites may use cookies, local storage, pixels or similar technologies. A separate Cookie Notice identifies the technologies in use, their providers, purposes and duration. The cookie interface permits users to make a real choice before non-essential technologies are activated.

Users may revisit and change cookie choices through a persistent settings control. Refusing non-essential cookies does not prevent access to ordinary website information.

11. Communications and direct marketing

UGMC distinguishes service communications from direct marketing. Appointment confirmations, responses to an enquiry, clinical instructions, security messages and important operational notices may be sent where necessary for the requested service or another lawful purpose.

Newsletters, promotional campaigns and optional messages from communications or public-relations teams are sent only where the recipient has given the required prior consent. Consent is not bundled into pre-registration or treatment conditions.

Every marketing message provides a simple method to unsubscribe. UGMC may retain a minimal suppression record after opt-out so that the person's preference can be respected and the person is not inadvertently added again.

12. Sharing and disclosure of personal data

UGMC does not sell personal data. UGMC may disclose personal data only where the disclosure is necessary, proportionate and lawful. Depending on the service, recipients may include:

• authorised UGMC clinicians, healthcare professionals, administrative teams and support personnel who require the information for their duties;
• laboratories, pharmacies, referral facilities, insurers, payers or other healthcare participants involved in an authorised episode of care;
• website hosting, cloud, cybersecurity, communications, SMS, email, live-chat, backup, payment and professional service providers;
• research sponsors, collaborators, ethics bodies or regulators under an approved protocol and appropriate safeguards;
• professional advisers, auditors, insurers and persons involved in the establishment, exercise or defence of legal claims;
• government departments, regulators, courts, law-enforcement bodies or public-health authorities where disclosure is authorised or required by law; and
• another person where disclosure is necessary to protect life, health, safety, property or legal rights and the law permits it.

UGMC limits disclosure, verifies authority and documents material disclosures as appropriate. Many lawful and necessary healthcare and service disclosures occur without a specific compulsory request.

13. Service providers and data processors

Some organisations process personal data on UGMC's behalf. UGMC conducts proportionate due diligence and uses written agreements requiring processors to:

• process data only on documented instructions and for authorised purposes;
• maintain confidentiality and appropriate security safeguards;
• restrict and monitor personnel access;
• notify UGMC promptly of suspected incidents or unauthorised processing;
• assist with rights requests, investigations, audits, retention and deletion;
• control subcontracting and provide relevant information about processing locations; and
• return, securely delete or de-identify data at the end of the service, subject to lawful retention requirements.

UGMC maintains an internal register of processors, purposes, systems, locations, contracts and review dates.

14. International and cross-border processing

Some service providers or collaborative partners may store or access data outside Ghana. Before allowing cross-border processing, UGMC assesses the destination, provider, purpose, sensitivity and available legal and contractual safeguards. UGMC seeks to ensure a level of protection appropriate to the information and the requirements of Act 843.

Where this is reasonably practicable and material to users, UGMC will identify the countries or regions involved, or explain how current transfer information can be obtained.

15. Information security

UGMC applies risk-based organisational and technical safeguards designed to protect personal data against accidental loss, unauthorised access, alteration, disclosure, destruction or unavailability. Measures may include:

• role-based access and least-privilege controls;
• identity verification, strong authentication and privileged-access management;
• encryption in transit and, where appropriate, at rest;
• secure configuration, patching, vulnerability management and malware protection;
• logging, monitoring, backup, recovery and business-continuity controls;
• confidentiality obligations, staff training and disciplinary procedures;
• vendor due diligence and processor oversight; and
• incident detection, containment, investigation, recovery and notification procedures.

No internet or information system can be guaranteed to be completely secure. Users should avoid sending highly sensitive medical information through ordinary email or an unauthorised messaging channel and should use designated UGMC services where available.

16. Data retention and secure disposal

UGMC retains personal data only for as long as is reasonably necessary for the purpose for which it was collected or subsequently lawfully processed. In deciding the appropriate period, UGMC considers:

• the purpose and continuing operational need;
• the nature, quantity and sensitivity of the information;
• the risk of harm from unauthorised use, loss or disclosure;
• healthcare, employment, financial, research, regulatory and records-management requirements;
• contractual obligations and applicable limitation or claims periods;
• the need to allow a reasonable opportunity to exercise access or correction rights; and
• legal holds, complaints, investigations, audits, litigation, public-health obligations and other lawful preservation requirements.

At the end of the approved period, UGMC will securely delete or destroy personal data in a manner intended to prevent reconstruction, or irreversibly de-identify it. Records retained for approved historical, statistical or research purposes will be protected against unauthorised access and use.

Deletion from active systems may not immediately remove data from disaster-recovery backups. Backup copies are isolated from ordinary use and removed through the approved backup-rotation process. Restoration from backup must not cause previously deleted data to re-enter ordinary use without appropriate controls.

17. Third-party websites and services

UGMC websites may link to external websites, social-media platforms, maps, payment services, research portals or applications. UGMC is not responsible for an independent third party's privacy practices merely because a link is provided. Users should review the privacy information supplied by that operator.

Where an external service is integrated into a UGMC page or receives information directly from UGMC, UGMC will assess whether the service acts as a processor, joint controller or independent controller and provide appropriate information about the arrangement.

18. Research, statistics and de-identification

UGMC may use personal data for ethically and legally approved research, service evaluation, audit, quality improvement or statistical purposes. A specific research notice and consent document will be provided where required and will explain the study purpose, data used, sharing, retention and withdrawal arrangements.

Where possible, UGMC will use aggregated, coded, pseudonymised or irreversibly anonymised data. Pseudonymised data remains personal data where re-identification is reasonably possible. Irreversibly anonymised information may be retained and used without the same individual-identification risks, provided the anonymisation is effective.

19. Changes to this notice

UGMC may update this notice to reflect changes in law, regulatory guidance, technology, services or processing activities. The current version will display an effective date and last-updated date. Where a change materially affects individuals, UGMC will take reasonable steps to provide additional notice before or when the change takes effect.

Earlier versions are retained internally so that UGMC can demonstrate which notice applied at a particular time.

20. Questions and complaints

Questions, concerns, rights requests or complaints may be sent to:

UGMC will investigate complaints fairly and seek to correct identified problems. You may also complain to the Ghana Data Protection Commission.