Parent Corporation: CRF Inc.
Subsidiaries: Entra Health Systems
- European General Data Protection Regulation (“GDPR”) assuring EU privacy via contracted Model Clauses.
- The US Health Information Portability & Accountability Act – HIPAA.
- The EU-U.S. Privacy Shield and Swiss-US Privacy Shield programs.
EHS respects individual privacy and values the confidence of its customers, employees, clinical trial participants, consumers, business partners and others. EHS strives to collect, use and disclose Personal Data in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices.
- All individuals who provide Personal Data including (but not limited to); customers, investigator site staff, clinical trial subjects, suppliers, job applicants and employees (past and present).
- EHS location in El Cajon, CA USA.
- Personal Data, in all media, from the point of receipt by EHS through processing and to final disposition (e.g., destruction or transfer of ownership of that data).
The EHS systems are developed and maintained in a manner that will ensure that EHS conducts its business in compliance with applicable data protection and confidentiality regulations and laws.
a) CRF HEALTH
Means CRF Inc., its successors, subsidiaries, divisions and groups. The parent company of EHS.
Means Entra Health Systems LLC, its successors, subsidiaries, divisions and groups.
c) EUROPE, EU, EUROPEAN ECONOMIC COMMUNITY (EEC), or EUROPEAN
Refers to a country in the European Union.
d) THIRD PARTY
Means any individual or entity
Means an employee (whether temporary, permanent, part-time, or contract), former employee, independent contractor, or job applicant of EHS or any of its affiliates or subsidiaries, who is also a resident of a country within the European Economic Area or United States.
f) PERSONAL DATA
As defined under the EU General Data Protection Regulation, means data that personally identifies or may be used to personally identify a person, including an individual’s name in combination with country of birth, marital status, emergency contact, address, phone number, e-mail address, user ID, password, and identification numbers. Personal Data does not include data that is de-identified, anonymous, or publicly available. For Switzerland, the term “person” includes both a natural person and a legal entity, regardless of the form of the legal entity.
g) PERSONAL HEALTH INFORMATION (PHI), INDIVIDUALLY IDENTIFIABLE HEALTH INFORMATION (IIHI) – HIPAA (US)
Any information about an individual including (1) any information that can be used to distinguish or trace an individual’s identity, such as name, social security number, date and place of birth, mother’s maiden name, or genetic/biometric records; and (2) any other information that is linked or linkable to an individual, such as medical, educational, financial, and employment information.
h) DATA SUBJECT
Means an identified or identifiable natural living person. An identifiable person is one who can be identified, directly or indirectly, by reference to a name, or to one or more factors unique to his or her personal physical, psychological, mental, economic, cultural or social characteristics. For Individual Customers residing in Switzerland, a Data Subject also may include a legal entity.
i) DATA CONTROLLER (EU)
Means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law. CRF Health acts as the data controller for EHS Personal Data and sensitive personal information that is not captured as part of supporting a clinical trial under the direction of a customer. CRF Health acts as the data controller for EHS’s Personal Data and sensitive personal information when it processes (or has a third-party process on its behalf) the Personal Data of its employees and customers.
j) DATA PROCESSOR (EU)
Means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller. EHS acts as the data processor for any personal and sensitive personal information captured as part of trial conduct, under the direction of the customer (Sponsor) in their capacity as DATA CONTROLLER.
k) BUSINESS ASSOCIATE, AGENT – HIPAA (US)
A person or entity that performs certain functions or activities that involve the use or disclosure of protected health information on behalf of, or provides services to, a covered entity. EHS acts as the business associate for any personal and sensitive personal information captured as part of trial conduct, under the direction of the customer in their capacity as a covered entity.
l) SENSITIVE PERSONAL INFORMATION
EHS will treat sensitive personal information as any information received from a third party where that third party treats and identifies the information as sensitive.
m) INDIVIDUAL CUSTOMER
Means an individual customer or client of EHS from EU or Switzerland. The term also shall include any individual agent, representative, of an individual customer of EHS and all employees of EHS where EHS has obtained his or her Personal Data from such Individual Customer as part of its business relationship with EHS.
Means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
3. Compliance with Legal Obligations
4. Types of Information Collected
EHS may collect Personal Data from sponsors, site personnel, employees, distributors, customers and end users, and pseudonymous sensitive personal information through clinical trials, reports or complaints, and general business activities. EHS takes appropriate action where unsolicited confidential data is received to prevent / minimize the risk of recurrence.
This includes all other identifiable and Personal Data other than clinical data. This includes (but may not be limited to) first name, last name, physical address, email address and telephone number of end user or investigator site staff, complainant information, visitors to the EHS website and employees, customers and suppliers.
5. Modes of Personal Data Capture/Storage
EHS captures Personal Data via different routes. The term “capture” shall be taken to encompass both solicited and unsolicited receipt of Personal Data.
EHS sees the Internet and the use of other technologies as necessary tools for communicating and interacting with consumers, customers, employees, healthcare professionals, business partners, and others.
The EHS website allows interested parties to request information and demonstrations of company services. The EHS MyHealthPoint Web Portal allows users to view content pertinent to the clinical trial through a secured website, should one be employed for a trial.
All employees are individually responsible for all electronic mail sent from their account and for the appropriate handling of personal data received into their account. Care should always be taken to evaluate whether e-mail is the most appropriate method for dissemination of Personal Data. Further detail is provided in the relevant security procedures and company handbook in relation to use of e-mail.
Where communication of information is by telephone, care will always be taken to evaluate whether this is the most appropriate method for discussion and / or dissemination of Personal Data.
5.3. Paper-based Information
Paper-based information that is current and required for ongoing study and/or general business activities are maintained, wherever possible, in locked cupboards or otherwise restricted areas; however, the EHS standard is to maintain records in electronic form. Paper is considered to be the backup to the electronic record. When paper information ceases to be required, it is destroyed confidentially, by shredding. Wherever appropriate and possible, printers that are not general access printers will be used to print such information
6. Receipt of unsolicited Personal Data and/or Sensitive Personal Information
The possibility of receipt of unsolicited Personal Data is acknowledged by EHS. Receiving, storing or further disseminating or otherwise processing such Personal Data may be incompatible with EHS’s commitment to the principles of transparency and purpose limitation, since the individual (data subject) may not be aware of the dissemination of that Personal Data to EHS. It is EHS policy, on receipt of such Personal Data to take all necessary actions to halt further processing or dissemination of that Personal Data and to prevent the risk of recurrence of same.
The individual receiving such Personal Data will, on receipt (and without further sharing the Personal Data, including to Quality Management) notify Quality Management or other designated Privacy Official and raise a corrective action (taking care not to capture any of the Personal Data in the corrective action) that Personal Data has been received, providing relevant information regarding the supplier of the Personal Data, circumstances of receipt and project (if applicable). At the same time, the Personal Data in question will be destroyed and the supplier notified that they have made an errant transfer of Personal Data.If the transmission contained other, non-identifiable data that is required by EHS, the supplier should be requested to re-supply without the personal identifiers. EHS Quality Assurance will monitor for any trends in unsolicited data to permit escalations as appropriate for repeated occurrences.
7. Access to Personal and Sensitive Personal Information
Access to information and systems is restricted to appropriate staff. For data held on the EHS network or servers, this is managed via R&D department.
In accordance with national and international laws, data subjects (individuals or groups to whom the Personal Data pertains) have the right of access to Personal Data EHS holds on them to ensure that it is accurate and up-to-date, to have the ability to request its correction/modification or to request deletion of all or part of that information if it is inaccurate or no longer necessary for the purposes for which EHS has collected the Personal Data.
8. Retention and Archiving of Information
EHS does not keep Personal Data any longer than necessary to meet the business purpose for which it was collected, unless legal or regulatory reasons require that the information not be deleted.
Where it is required that information is not deleted, EHS will retain that information for the minimum period required by law or regulation.
In the case of clinical data, on transfer of ownership of information back to a Sponsor or Investigator, it shall be deemed that the new owner becomes responsible for assuring the confidentiality and security of the information.
9. Training and Awareness
10. Clinical Trial Subject Data Obligations
Personal Health Information collected within the US is pseudo-anonymised by patient ID. Some additional HIPAA personal information is collected for patient SMS reminders but this information is obfuscated within the computer systems viewable by only the patients and their authorized investigators. All US data will be managed the same as EU data as all data is stored (processed) within the EU and becomes subject to EU legislation.
12. GDPR Model Clauses
The European Commission is empowered to recognize standard contractual clauses (known as model contract clauses) as offering adequate safeguards for the purposes of Article 46 of the GDPR. The European Commission has approved model contract clauses (EU Decision 2002/16/EC) that can be used by data exporters and data importers to transfer data outside the EEA. Where processing Personal Data is involved EHS utilizes the appropriate model contract clauses (controller to controller and controller to processor) between its affiliates and with its customers and vendors to provide adequate safeguards for the processing of Personal Data.
EHS policy is to follow the higher standard where applicable.
12.1. Data Transfer Mechanism
12.2. Model Clauses GDPR Principles
12.2.1. Data Controller
Where EHS is a data controller with respect to Personal Data from individuals in the EEA, it will inform them about the purposes for which it collects and uses this information about them, the types of non-agent third parties to which EHS discloses that Personal Data, whether it intends to transfer Personal Data to a third country and the choices and means, if any, EHS offers individuals for limiting the use and disclosure of their Personal Data.
Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Data to EHS, or as soon as practicable thereafter, and in any event before EHS uses or discloses the information for a purpose other than that for which it was originally collected.
Where EHS receives Personal Data from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such Personal Data relates.
12.2.2. Purpose Limitation
EHS process’ Personal Data and subsequently use Personal Data only for specified purposes or as subsequently authorized by the data subject.
12.2.3. Data Quality and Proportionality
EHS ensures that Personal Data is accurate and, where necessary, kept up to date. The Personal Data must be adequate, relevant and not excessive in relation to the purposes for which they are processed.
EHS will provide data subjects with information designed to ensure fair processing, such as information about the purpose of processing and data transfer.
12.2.5. Rights of Access, Rectification, Deletion and Objection
EHS take reasonable precautions designed to ensure that Personal Data processed by EHS is accurate and, where necessary, kept up to date. EHS will take every reasonable step to ensure that Personal Data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without unreasonable delay. EHS will provide data subjects with personal information about them that EHS holds, except for requests which are manifestly abusive, based on unreasonable intervals or their number or repetitive or systematic nature, or for which access need not be granted under the law.
12.2.6. Security and Confidentiality
EHS will take reasonable precautions to process Personal Data in a way designed to ensure appropriate protection of personal and/or sensitive information in its possession, including protection from accidental loss, misuse and unauthorized access, disclosure, alteration and destruction.
This will be achieved via appropriate physical and logical security mechanisms.
Computer systems, equipment, networks, programs, data, and documentation are secured to the extent reasonably possible using existing technology.
Where Personal Data is to be transferred on physical media, the media will be kept away from any means of reading that information and appropriate password protection, encryption, or other means used to minimize the risk of unauthorized access to that information.
Further details of security mechanisms for transfer of Personal Data electronically and transport by employees of Personal Data is addressed in the applicable security QMS documents.
12.2.8. Dispute Resolution
13. Privacy Shield Policy
Entra Health Systems LLC d.b.a Entra Health or EHS has adopted this Privacy Shield Policy (“Policy”) to establish and maintain an adequate level of Personal Data privacy protection. This Policy applies to the processing of Personal Data that EHS obtains from Customers located in the European Union and Switzerland.
EHS complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
The Federal Trade Commission (FTC) has jurisdiction over EHS compliance with the Privacy Shield.
All EHS employees who handle Personal Data from Europe and Switzerland are required to comply with the Principles stated in this Policy.
This Policy applies to the processing of Individual Customer Personal Data that EHS receives in the United States concerning Individual Customers who reside in the European Union and Switzerland.
13.2. RESPONSIBILITIES AND MANAGEMENT
EHS VP Quality Assurance and Regulatory Affairs (VP RAQA) or Management designee will oversee its information security program, including its compliance with the EU-US Privacy Shield and Swiss-US Privacy Shield Programs. The VP RAQA shall review and approve any material changes to this program as necessary. Any questions, concerns, or comments regarding this Policy also may be directed to email@example.com
EHS will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects.
13.3. RENEWAL / VERIFICATION
EHS, under CRF Inc., will renew its EU-US Privacy Shield and Swiss-US Privacy Shield certifications annually, unless it subsequently determines that it no longer needs such certification or if it employs a different adequacy mechanism.
Prior to the re-certification, EHS will conduct an in-house verification to ensure that its attestations and assertions with regard to its treatment of Individual Customer Personal Data are accurate and that the company has appropriately implemented these practices. SpecificallyAs part of the verification process, EHS will undertake the following:
c) Ensure that this Policy continues to comply with the Privacy Shield principles.
d) Confirm that Individual Customers are made aware of the process for addressing complaints and any independent dispute resolution process (EHS may do so through its publicly posted website, Individual Customer contract, or both).
COLLECTION AND USE OF PERSONAL DATA
EHS may collect Personal Data from sponsors, site personnel, employees, distributors, customers and end users, and sensitive personal information through clinical trials, reports or complaints, and general business activities.. EHS takes appropriate action where unsolicited confidential data is received to prevent / minimize the risk of recurrence. See Sections 3 and 4 of this Policy for further details.
13.4. DISCLOSURES / ONWARD TRANSFERS OF PERSONAL DATA
Except as otherwise provided herein, EHS discloses Personal Data only to Third Parties who reasonably need to know such data only for the scope of the initial transaction and not for other purposes. Such recipients must agree to abide by confidentiality obligations.
EHS may provide Personal Data to Third Parties that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. For example, EHS may store such Personal Data in the facilities operated by Third Parties. Such Third Parties must agree to use such Personal Data only for the purposes for which they have been engaged by EHS and they must agree, via written contract, to provide adequate protections for the Personal Data that are no less protective than those set out in this Policy.
EHS also may disclose Personal Data for other purposes or to other Third Parties when a Data Subject has consented to or requested such disclosure. Please be aware that EHS may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. EHS is liable for appropriate onward transfers of Personal Data to third parties.
13.5. DATA INTEGRITY AND SECURITY
EHS uses reasonable efforts to maintain the accuracy and integrity of Personal Data and to update it as appropriate. EHS has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alternation, or destruction. For example, electronically stored Personal Data is stored on a secure network with firewall protection, and access to EHS electronic information systems requires user authentication via password and appropriate role, or similar means. EHS also employs access restrictions, limiting the scope of employees who have access to Individual Customer Personal Data.
Further, EHS uses secure encryption technology to protect certain categories of Personal Data. Despite these precautions, no data security safeguards guarantee 100% security all of the time.
13.7. ACCESSING PERSONAL DATA
EHS personnel may access and use Personal Data only if they are authorized to do so and only for the purpose for which they are authorized.
13.8. RIGHT TO ACCESS, CHANGE OR DELETE PERSONAL DATA
13.8.1. Right to Access
Individual Customers have the right to know what Personal Data about them is included in the databases and to ensure that such Personal Data is accurate and relevant for the purposes for which EHS collected it. Upon reasonable request and as required by the Privacy Shield principles, EHS allows Individual Customers access to their Personal Data by contacting EHS by phone or email. To request erasure of Personal Data, Individual Customers should submit a written request to the EHS office in El Cajon, CA USA.
13.8.2. Requests for Personal Data.
EHS will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise: (a) legally binding request for disclosure of the Personal Data by a law enforcement authority unless prohibited by law or regulation; or (b) requests received from the Data Subject. If EHS receives a request for access to his/her Personal Data from an Individual Customer, then, unless otherwise required under law or by contract with such Individual Customer, EHS will refer such Data Subject to the Individual Customer.
13.8.3. Satisfying Requests for Access, Modifications, and Corrections.
EHS will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.
13.9. ENFORCEMENT AND DISPUTE RESOLUTION
In compliance with the EU-US Privacy Shield and Swiss-US Privacy Shield Principles, EHS commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this Policy should first contact EHS at: firstname.lastname@example.org
If a Customer’s question or concern cannot be satisfied through this process, EHS has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
If your complaint is not satisfactorily addressed, and your inquiry or complaint involves human resource data, you may have your complaint considered by an independent recourse mechanism: for EU/EEA Data Subjects, a panel established by the EU data protection authorities (“DPA Panel”), and for Swiss Data Subjects, the Swiss Federal Data Protection and Information Commissioner (“FDPIC”). To do so, you should contact the state or national data protection or labor authority in the jurisdiction where you work. CRF Health agrees to cooperate with the relevant national DPAs and to comply with the decisions of the DPA Panel and the FDPIC.
Should your complaint remain fully or partially unresolved after a review by EHS, BBB EU Privacy Shield and the relevant DPA, you may be able to, under certain conditions, seek arbitration before the Privacy Shield Panel. For more information, please visit www.privacyshield.gov.
15. QUESTIONS OR COMPLAINTS
If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact our Privacy & Security Officer at email@example.com or by mail at:
Entra Health Systems LLC
Attention: Privacy & Security Officer
1300 North Johnson Avenue, Suite 100 El Cajon, CA 92020
2. EHS’S ONLINE PRIVACY COMMITMENT TO YOU
- Why does EHS collect and use Personal Information?
Collection We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Personal Information by filling in forms or by corresponding with us by post, phone, and email or otherwise. This includes Personal Information you provide when you:
- request for our products or services;
- request marketing or surveys to be sent to you;
- give us some feedback; or
- use our websites (https://entrahealth.com or www.myhealthpoint.com)
- Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. This information does not reveal your specific identity. We collect this Personal Information by using server logs and other similar technologies.
- Third parties or publicly available sources. We may receive Personal Information about you from various third parties.
- Identity data from data brokers or aggregators.
- Public sources. We may identity data from publicly availably sources.
|Purpose / activity||Type of Personal Information||Basis for use and processing|
|Providing our services and managing our relationship with you: – to provide services or goods to you; – to respond to your enquiries and fulfill your requests, when you contact us for example, when you send us questions, suggestions, or feedback, or when you request a quote, or other information about, our services.||– Name – Address – Email address – Telephone / mobile number(s) – Professional title||Necessary for our legitimate interests (for providing our services, running our business, and for administrative purposes)|
|Contacting suppliers||– Name – Email addresses – Telephone / mobile numbers – Job title / position of responsibility – Social media profile(s)||Necessary for our legitimate interests (for providing our services, running our business, and administrative purposes)|
|In connection with the sale, assignment, or other transfer of the business to a third party||– Name – Address – Email address – Telephone / mobile number(s)||Necessary for our legitimate interests (maintaining revenue, dealing with potential purchasers)|
- Who will have access to Personal Information about me?
Personal Information about you will be accessible to EHS, including its subsidiaries, and affiliates worldwide. EHS may also share such Personal Information with its agents, contractors, service providers or business partners, in connection with services that these individuals or entities perform for, or with, EHS. We require all third parties to respect the security of your Personal Information and to treat it in accordance with the law. In such circumstances, we do not allow our third-party service providers to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions.
- How does EHS secure your Personal Information?
We use appropriate security measures to protect against the loss, misuse and alteration of data used by our system. It is your personal responsibility to secure your own copies of your passwords and related access codes for our online resources. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with Section (13) below.
- How can you stop receiving e-mails or other marketing information from EHS?
If you wish to stop receiving emails or other marketing information from us please email firstname.lastname@example.org.
- How may I access and correct Personal Information about me?
To gain access to your Personal Information, which EHS has collected online, and to keep it accurate, complete and current, you may contact us at email@example.com In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. There may also be residual information that will remain within our databases and other records, which will not be removed. Where permitted by law, your ability to access and correct Personal Information will be limited where access and correction would: (i) inhibit EHS’s ability to comply with a legal or ethical obligation; (ii) inhibit EHS’s ability to investigate, make or defend legal claims, result in disclosure of Personal Information about a third party; or (iii) result in breach of a contract or disclosure of trade secrets or other proprietary business information belonging to EHS or a third party.
- Sensitive Personal Information
While we operate in the healthcare industry, which can involve sensitive Personal Information, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.
- Other information
- Retention Period
We will retain your Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and provide the Services to you; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
- Jurisdiction and cross border transfers
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information. If you are located in the European Economic Area (EEA): Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information.
- How does EHS protect the privacy of children?
Children under the age of 18 should only access our site only when initiated by an adult parent or guardian. Entra Health Systems will not knowingly collect or use any personal information from individuals under the age of eighteen without the consent of a parent or guardian, or provide any personally identifying information collected from children, regardless of its source, to any third party for any purpose. If a visitor submits information to the web site through the registration process that indicates the visitor is a child, the child’s parent or guardian email is required and will be alerted to the child’s registration and will be provided instructions on how the parent or guardian can delete the child’s registration, if so desired. Entra Health Systems does not require a child to disclose more information than is reasonably necessary to participate in an activity.
- Parental Access
- What is EHS’s contact address for privacy questions?
- contact our Privacy & Security officer at firstname.lastname@example.org
- lodge a complaint with a supervisory authority competent for your country or region.
- No representations / No liability