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The Encode Health Privacy Policy

The Encode Health privacy policy for electronic health records is to treat primary records as being under the control of the data subject through the Healthcare Passport.

This provides the facility for the holder to control who can view their records and under what circumstances.

Having collected a medical record we would in fact not be able to delete it under the Records Management Code of Practice for Health and Social Care 2016, but access to the record could be restricted by the data subject.

During the original collection of the data, the data subject would need to agree to providing analytical access and to the results of any COVID-19 test to public health applications for a minimum period of 1 year. After this period, the data subject would need to confirm any ongoing access and could rescind access to analytical applications at any time.

During the contract period we would have collected personal data from subjects with their permission and their medical records which fall under the Records Management Code of Practice for Health and Social Care 2016.

Our essential premise is that access to clinical records is under the control of the data subject and that only under very limited circumstances can restrictions be overridden. Because of the Limitations Act, clinicians and institutions must be granted continued access to records created under their auspices. Beyond such legal access however, everything is under the control of the Healthcare Passport holder.

At the end of the COVID-19 solutions contract we would expect to disengage any government connection to the primary data.


Last update: July 2020


Modern Slavery Statement

Encode Health is issuing this statement pursuant to the UK Modern Slavery Act, to disclose efforts ensuring that modern slavery is not taking place in our supply chains and business operations.

As a result, statements regarding Encode Health’s efforts to ensure that modern slavery is not taking place in its supply chains and business operations—including statements regarding the company’s policies, processes, and procedures. Throughout this statement we reference “modern slavery,” which includes slavery, servitude, forced or compulsory labor, and human trafficking. In addition, we reference “contingent workforce suppliers” and “contingent workers,” which includes suppliers and supplier employees that work at Encode Health facilities.

Supplier Risk Assessment We evaluated our contingent workforce suppliers for labor and modern slavery risk, and processed higher-risk suppliers through internal due diligence evaluations of suppliers.

Encode Health generates revenue primarily from sales of digital content and our cloud services. Our anti-modern slavery efforts require strong collaboration and engagement with our global suppliers that manufacture products or provide services that we engage with.

Our philosophy, similar to other cloud based services is to work in partnership with our suppliers, empowering them to establish programs, policies, and practices that mitigate the risk of modern slavery occurring in their supply chains.

Internal management, accountability, and programs. Our Ethics team and Compliance Officer continues to oversee a team focused on combating modern slavery in our supply chains and business operations.

The Chief Ethics and Compliance Officer provides quarterly updates on the status of our Anti-Modern Slavery Program to our Compliance Steering Committee, composed of senior executives from across our business.

Policies addressing ethical conduct and prevention of modern slavery As reported in our previous statements, we have an Employee Code of Conduct and a Supplier Code of Conduct.

Our Supplier Code of Conduct sets standards designed to protect the health, safety, and treatment of workers, including the prohibition of any form of modern slavery, including forced, bonded (including debt bondage), or indentured labor; involuntary prison labor; sex trafficking; and slavery or trafficking of people. We strive to hold our employees and suppliers to high standards. Any violation of our standards by a Encode Health employee can result in disciplinary action, including termination of employment. Any violation by a supplier can result in contract termination.

Our assessment processes involve review and analysis to identify higher-risk areas of our business based on external reports and standards, country and sector risk profiles, and input from experts in this area. We train workers to conduct due diligence to identify and avoid working with third parties that engage in modern slavery or other illegal practices.

Reporting concerns or raising issues related to modern slavery We offer multiple reporting options to workers, including a helpline that gives callers an option to report concerns anonymously. We promote these reporting options through our internal policies, communications, and trainings. We are also developing a policy prohibiting retaliation for raising concerns.


Last update: July 2020

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