1. Data Protection Policies

To safeguard sensitive information and maintain the integrity of data, Real Health Uganda has implemented comprehensive data protection measures. These policies are designed to protect the privacy of individuals and ensure that data is secure at all stages of its lifecycle.

a. Encryption:

  • Data-at-Rest Encryption:
    All sensitive data stored within Real Health Uganda’s databases is encrypted using industry-standard encryption algorithms. This ensures that, even if unauthorized access is gained, the data remains unintelligible and secure.
  • Data-in-Transit Encryption:
    Any data transmitted between systems, whether internally or externally, is encrypted using Secure Socket Layer (SSL) or Transport Layer Security (TLS) protocols. This prevents interception and unauthorized access during transmission.

b. Access Controls:

  • Role-Based Access Control (RBAC):
    Access to sensitive data is restricted based on the user’s role within the organization. Each role is granted only the permissions necessary to perform specific tasks, minimizing the risk of unauthorized access.
  • Multi-Factor Authentication (MFA):
    To further protect access to systems containing sensitive data, Real Health Uganda employs MFA. This requires users to verify their identity through two or more methods, such as a password and a code sent to a mobile device.
  • Audit Trails:
    All access to sensitive data is logged, creating a detailed audit trail that tracks who accessed the data, when, and what actions were taken. These logs are regularly reviewed to detect and respond to any unauthorized access attempts.

c. Secure Storage:

  • Data Segmentation:
    Sensitive data is stored separately from non-sensitive data, using dedicated storage solutions that are specifically designed to enhance security.
  • Regular Security Assessments:
    Real Health Uganda conducts regular security assessments, including penetration testing and vulnerability scans, to identify and address potential security weaknesses in its data storage systems.

d. Data Backup and Recovery:

  • Encrypted Backups:
    Regular backups of sensitive data are encrypted and stored securely. This ensures that, in the event of a data breach or system failure, the data can be restored without compromising security.
  • Disaster Recovery Plan:
    A comprehensive disaster recovery plan is in place to ensure that data can be quickly and securely restored in the event of a system failure, natural disaster, or cyberattack.

2. Compliance with Regulations

Real Health Uganda is committed to complying with all relevant local and international data protection regulations. This ensures that the organization’s data handling practices are lawful, ethical, and aligned with global standards.

a. General Data Protection Regulation (GDPR):

  • Personal Data Protection:
    For any data processing activities involving individuals within the European Union (EU), Real Health Uganda adheres to the principles of the GDPR. This includes ensuring that personal data is processed lawfully, transparently, and for a specific purpose.
  • Data Subject Rights:
    The organization respects the rights of data subjects under the GDPR, including the rights to access, rectify, and erase their personal data. Processes are in place to respond to data subject requests within the required timeframes.

b. Health Insurance Portability and Accountability Act (HIPAA):

  • Protected Health Information (PHI):
    For data involving U.S. individuals, Real Health Uganda complies with HIPAA regulations concerning the handling of PHI. This includes implementing safeguards to protect PHI from unauthorized access, use, or disclosure.
  • Breach Notification:
    In the event of a data breach involving PHI, Real Health Uganda follows HIPAA’s breach notification requirements, including notifying affected individuals and relevant authorities within the specified timeframe.

c. Uganda Data Protection and Privacy Act (2019):

  • Data Subject Consent:
    Real Health Uganda ensures that personal data is collected and processed with the explicit consent of the data subject, as required by Uganda’s Data Protection and Privacy Act. This includes providing clear and transparent information about how data will be used.
  • Data Processing Agreement (DPA):
    The organization has established DPAs with any third parties involved in data processing activities, ensuring that they also comply with Uganda’s data protection regulations.

d. Regular Compliance Audits:

  • Internal Audits:
    Real Health Uganda conducts regular internal audits to assess compliance with data protection regulations. These audits review data handling practices, access controls, and consent management processes.
  • External Audits:
    The organization also undergoes periodic external audits by accredited third parties to verify compliance with relevant regulations and standards.

3. Anonymization

To protect individual privacy while still allowing for valuable data analysis, Real Health Uganda employs rigorous anonymization techniques. These methods ensure that personal data is stripped of identifying information, reducing the risk of re-identification.

a. Data Anonymization Techniques:

  • Data Masking:
    Personal identifiers, such as names, addresses, and national identification numbers, are replaced with pseudonyms or masked to prevent identification of individuals.
  • Aggregation:
    Data is aggregated to a higher level, such as summarizing data by geographic region or demographic group, rather than at the individual level. This reduces the granularity of the data, making it less likely that individuals can be re-identified.
  • Data Suppression:
    In cases where data is too sensitive or where anonymization would not be sufficient to protect privacy, certain data points may be suppressed or omitted entirely.

b. De-identification:

  • Direct Identifier Removal:
    All direct identifiers, such as names, phone numbers, and email addresses, are removed from datasets before they are used for analysis or shared with third parties.
  • Indirect Identifier Management:
    Indirect identifiers, such as dates of birth or zip codes, are carefully managed to prevent the combination of data points that could lead to re-identification.

c. Anonymization Best Practices:

  • Re-Identification Risk Assessment:
    Before data is anonymized, a risk assessment is conducted to evaluate the likelihood of re-identification. This assessment informs the choice of anonymization techniques and the level of data detail that can be safely retained.
  • Regular Anonymization Review:
    Anonymization processes are regularly reviewed and updated to reflect advances in technology and changes in regulatory requirements. This ensures that the organization’s practices remain effective and compliant.

d. Secure Anonymized Data Sharing:

  • Controlled Access:
    Anonymized data is shared with external researchers or partners only under strict conditions. Access is controlled, and recipients are required to sign data use agreements that prohibit attempts to re-identify individuals.
  • Data Sharing Transparency:
    Real Health Uganda maintains transparency about its data sharing practices, informing data subjects when their anonymized data may be shared for research or other purposes.