Policy on Collection and Use of Personal Information
The J.F. Shea Center Therapeutic Riding Center (SHEA CENTER) values and respects an individual’s right to keep certain Personal Information private. Likewise, the SHEA CENTER values the need to collect and use Personal Information which will enable the SHEA CENTER to effectively deliver products and services leading to a reduction in disability. “Personal Information” is “Demographic Information” and/or “Medical Information” which identifies a specific individual with a minimal degree of effort. Demographic Information includes name, address, city and other similar information. Medical Information includes diseases, treatments, lifestyle behaviors, family history, genotype, phenotype and other similar information. Transactional Information is data collected on an individual based on the individuals’ interactions with the SHEA CENTER. Aggregate Information is information in summary form which does not contain data that would permit the identification of a specific individual.
A. SHEA CENTER Collection of Personal Information
The SHEA CENTER will collect Personal Information on an individual only if the individual provides the information to the SHEA CENTER. Notwithstanding, the SHEA CENTER does collect Demographic Information.
B. SHEA CENTER Use of Personal Information
1. When an individual provides Personal Information to the SHEA CENTER, the SHEA CENTER may use the Personal Information for its programs, research and fund raising.
2. Unless an individual gives permission, the SHEA CENTER will not allow any third party to use Personal Information collected by the SHEA CENTER.
3. The SHEA CENTER does not allow third parties to use Aggregate Information.
4. The SHEA CENTER uses Transactional Information for research purposes for the development or implementation of its programs, products and services. The presumption is that since Transactional Information is highly proprietary, it will not be disclosed to third parties.
5. The SHEA CENTER will disclose all information as required by law.
6. The SHEA CENTER will suppress the use of an individual’s Personal Information if requested by that individual.
C. Specific Requirements
1. Administrative Requirements
(a) All Personal Information collected on individuals will be kept confidential and in a secure environment.
(b) Access to Personal Information will be restricted to only those personnel with a legitimate business purpose.
2. Scientific Research Requirements
Any research funded by the SHEA CENTER that involves human subjects (e.g., information collected on individuals) must be endorsed by the sponsoring institution’s committee on clinical investigation or other appropriate body, and conform ethically to the guidelines prescribed by the National Institutes of Health, which includes obtaining informed consent from each individual.
3. Third Party Disclosure Requirements
Permission is required before the SHEA CENTER discloses Personal Information to a third party. No permission is necessary for Aggregate Information, since Aggregate Information does not identify a specific individual.
(a) For disclosure of Medical Information, Informed Consent is required before the SHEA CENTER discloses Medical Information to a third party. Informed Consent occurs when an individual has sufficient facts about the disclosure, comprehends those facts, and voluntarily consents to the disclosure. Where a third party such as the employer or healthcare provider of an individual requires the individual to participate in a SHEA CENTER program which collects Medical Information, the SHEA CENTER will require the employer or healthcare provider to procure Informed Consent before the SHEA CENTER will release Medical Information to that employer or healthcare provider.