Privacy & Cookies
PRIVACY & COOKIESThe International SOS Group of Companies provides services to our members through our worldwide network of assistance centres, clinics, health and logistics providers. We offer local expertise, preventative advice, and emergency assistance during critical illness, accident, or civil unrest globally. Our clients include businesses, governments and non-governmental organizations who require access to international standards of medical assistance and travel security services. The companies in our corporate group, which are each established in their respective local jurisdiction in compliance with required local legal requirements, collect, hold, use and disclose your personal information in a number of different ways.
We are committed to ensuring that your personal information is protected.
Our privacy statement provides you with information about how the numerous companies in the International SOS Group manage your personal information. It also describes your choices regarding use, access and correction of your personal information. We encourage you to read this statement which describes:
- The personal data that we collect
- How we collect data and why
- How data will be used and who we can disclose or transfer data to and why
- How data can be corrected or deleted
- The reasons why data is transferred across our network
- The measures that we take to protect data
- The process and contact information that customers can use to raise enquiries, concerns and complaints
1. Commitment to personal data protectionInternational SOS is committed to safeguarding our customers' personal data by adherence to the following obligations:
- The International SOS Data Protection Policy, the Information Security Policy and the related policies;
- The Binding Corporate Rules sanctioned by the European Community's data protection authorities;
- The relevant local data protection laws and regulations; and
- The contractual commitments to our customers.
International SOS Binding Corporate Rules were approved by the European Commission in 2010. For more information please contact us.
The ‘International SOS’ branded Group of Companies consists of independently managed companies in over 70 countries, and includes several entities incorporated in the United States of America such as International SOS Inc, Aspire Lifestyles Inc, MedAire, Inc and International SOS Government Services Inc and International SOS (The Americas) LP (“US Entities”). These companies are licensed to use the ‘International SOS’ brand, and references to ‘International SOS’ are to the brand and the separate entities which comprise the International SOS Group of Companies.
The US Entities also complies with the U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from Switzerland. International SOS Assistance, Inc. has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view International SOS Assistance, Inc.’s certification, please visit https://safeharbor.export.gov/swisslist.aspx.
2. To whom this statement applies
3. What information is collected and how is it collected?
International SOS collects personal data about you when you purchase, use or benefit from International SOS's services or products. We may also receive information about you from other sources when this data is given to International SOS by third parties, such as companies employing you or your relatives, insurance companies, private medical insurers, assistance companies, financial institutions, medical service providers, travel agencies and similar companies, that are permitted to share this personal data.
"Personal data" includes information that will allow someone to identify or contact you, including, for example, your full name, address, telephone number (professional & home) or email address, gender, date of birth, nationality, family status (dependent), industry sector information related to professional activity, status (expatriate or traveller) and destinations.
Personal data does not include aggregated data or data that, by itself, does not permit the identification of individual persons, such as statistics on the number of expatriates and travellers that are eligible in a member company to receive assistance services or the number of people visiting the International SOS website each month.
You provide certain personal data to International SOS when, for example, you: (a) call our assistance centres or clinics; visit our clinics; visit our facilities at remote sites providing services under a medical services contract; seek a consultation with our medical professionals; and travel with our medical escorts (b) contact us as part of a health assessment; (c) contact us to receive medical consultancy and patient support services; (d) contact us to receive security consultancy and security services; (e) order services and products from International SOS websites; (f) submit forms through our web sites; (g) access services through a downloadable electronic application for mobile devices ("App"); (h) attend our medical and security training courses ; (i) seek assistance with your insurance claims; or (j) make enquiries, requests or complaints.
Subject to your agreement to the applicable terms and conditions, you may access services through the App, including but not limited to travel health and security information and other services which may be added by International SOS from time to time.
The App provides personal information including your or your organization's International SOS Membership Number, as well as the email address of your mobile device. To enable location-specific services, the App also collects and divulges your location. The App also periodically provides information concerning your usage of particular App features.
When you choose to pay for International SOS services or products by credit card directly from the International SOS website, you will be required to provide International SOS with the name of your credit card issuer, credit card number, expiration date and other security information. When you choose to pay for International SOS services or products by other means, we may ask you for your credit card details, contact details and bank account details.
You also provide information to us when you choose to email data to us, or you participate in marketing and sales initiatives.
International SOS will only gather data that is relevant for the purposes for which it will be used and will not gather excessive or unnecessary data.
International SOS shall take reasonable steps to ensure that data is reliable, accurate, complete, and current, bearing in mind its intended use. You have a responsibility to keep the data you provide to us updated and we will take reasonable steps to facilitate this.
4. Acceptance and links to other websites
International SOS website may contain links to other websites, which are provided solely as a convenience to you and not as an endorsement by International SOS of the contents of other web sites. The other web sites may have their own policies, which International SOS does not control, and thus are not addressed or controlled by this statement or the International SOS Data Protection Policy.
5. Cookies and Tracking Technologies
6. How the Personal Data will be used
International SOS will use your personal data to provide you with services and products that: (a) you purchase; (b) are purchased by your employer or your relative's employer; (c) are purchased by an association or institution (including an educational establishment) of which you are a member; (d) are part of services provided through an insurance program or as part of financial services that are provided to you.
Many of these services and products are designed to provide tools for risk management by providing medical and security assistance.
International SOS may collect or you may provide to International SOS, medical data to provide medical assistance, managing medical and health assessment reports, create an emergency medical record, or data about your travel plans to enable International SOS to provide you with security assistance and travel information and support. We may also gather your personal data to assist us in managing services or products provided to you or your employer.
The personal information collected from the App enables International SOS to provide better and more relevant services. Location information collected by the App is used to provide the best assistance centre number for you to call as well as to provide medical and security alerts and other information relevant to your location. If you opt-in to Location Check-in (where available), location information may also be collected and used to help locate you in emergency situations or where your life or safety may be jeopardized. The usage information is used to help International SOS better understand how you make use of the App, in order to make improvements to it.
Your personal data may be transferred to companies within the International SOS Group of Companies or to service providers that are performing services for International SOS or acting as International SOS's agents, which may be located in a country outside of your country of origin. International SOS will require that any such service providers agree to keep your personal data secure and confidential, use it only for the purposes for which the personal data is transferred and use it only in accordance with International SOS's directions.
With your consent and in compliance with relevant personal data protection and privacy laws, for similar purposes as those outlined above, your personal data may also be transferred to: your employer; or your relative's employer; or the insurance company; or private medical insurer; or credit card company or other financial institution; or the association or other institution or company that purchased the International SOS services or products on your behalf or under which you receive the benefit of such services or products.
Your personal data may be transferred to Government authorities, agencies and institutions as required or permitted by applicable laws and regulations.
International SOS shall not collect, use, disclose or transfer your personal data except as described in this Statement unless you give us your permission to collect, use, disclose or transfer it for other purposes.
7. Data protection for children
International SOS does not knowingly collect any information on persons who have not attained the age of 18 years through the online services and the International SOS website.
8. What choices are available to users regarding collection, use, storage, disclosure or transfer of the Personal Data?
You are given the opportunity to choose or 'opt-in' to have sensitive personal data (such as medical data) collected, used, stored, disclosed or transferred for purposes of providing services and products at the point where we ask you for the sensitive personal data. The collection of personal data through our online service for the emergency medical records will include an 'opt-in' mechanism for you to give us your consent to use and disclose your personal medical data to enable us to provide you with medical care and related services. We may, by way of example, transfer your medical data to other companies in the International SOS group, service providers that provide medical services, travel services or to local clinics or doctors who we arrange to treat you or provide you with a health assessment. We may also transfer personal data to local authorities if necessary or desirable to assist in arranging emergency medical care for you.
You may also 'opt-out' of receiving our services and products.
You may sign-up to receive email or newsletter from us. If you would like to discontinue receiving this information, you may update your email preferences by replying to the email or clicking the "unsubscribe" link found in emails we send to you.
We may collect your personal medical data from you or from other sources with your permission. We may disclose that data to other companies in the International SOS group of companies and to service providers that provide security, travel and medical services, in order to manage the services and products that we provide.
You will also be given the choice to prohibit International SOS from disclosing your personal data to a third party or for purposes other than to provide International SOS services and products.
Note that if you choose to 'opt-out', withhold, block or request that we delete your personal data, you may not be able to receive the benefit of International SOS's services and products.
International SOS collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.
9. How can users correct inaccuracies in their Personal Data?
You can review the personal data that International SOS has collected from you by contacting our: assistance centre; customer service personnel; clinic; medical service facility; or sales person; or by using your password to access your records through our website.
Upon request, International SOS will provide you with information about whether we hold any of your personal information. In order to update, delete, amend or block any personal information that we create and that we are able to change, contact us using the following e-mail address: firstname.lastname@example.org or through the contact link on our website. Should you need our assistance to access or make changes to your personal information, please submit your request to us. Corrections or deletions of data resulting solely from errors by International SOS or our service providers shall be paid for by International SOS.
If you do not wish to contact International SOS through our website, you may contact our Data Protection Officers who are also our Country General Managers, responsible for the country in which you are residing or receiving products or services. You can contact our Data Protection Officers at the following e-mail address: email@example.com.
International SOS acknowledges that you have the right to access your personal information. International SOS has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the International SOS’ Client (the data controller). In making your request to review, update, amend or block data, you will be required to provide International SOS with details of the data requested and the reasons why the data needs correction. International SOS will ask for proof of your identity. International SOS may ask you to assist in verifying the accuracy of the updates and the amendments to the personal data.
International SOS may ask you to cover the reasonable cost of accessing and providing copies of your personal data if this is not provided through the International SOS website.
International SOS will strive to address your request as soon as practicable and no later than thirty (30) calendar days from the date your request is received and understood.
If International SOS is asked to destroy the personal data, International SOS shall use means that prevents its recreation and International SOS shall take reasonable care to ensure that there is no unauthorised disclosure during the destruction of the data.
10. What kind of security procedures are used to protect the loss, misuse, or alteration of your personal data under International SOS's control?
International SOS takes precautions to protect its users' information. International SOS has implemented policies that forbid its employees from using or disclosing personal data in an inappropriate or unlawful manner and maintains security measures to safeguard the personal data that it maintains from unauthorized access, misuse, alteration, loss or destruction. If you have any questions about the security of your personal information, you can contact us at firstname.lastname@example.org.
Information collected by electronic means
When you provide International SOS with personal data through online forms and other electronic methods, the data is protected using industry-standard encryption.
The Information Security Policy, Procedures and Processes
All International SOS employees are required to follow the Information Security Policy. The policy is implemented through the Information Security procedures and processes. These are periodically reviewed and updated, as the information security landscape is in a constant state of flux. All new employees are required to sign a written confirmation that they have read and understood the Information Security Policy and a confidentiality agreement. Employees also have confidentiality obligations in their contracts of employment with International SOS.
Security of premises and other physical security measuresPhysical access to all International SOS offices, assistance centres, clinics, medical services sites and other facilities are security controlled which include locks that are opened by keys and by using security cards and security card readers that record the identity of employees and visitors entering or leaving the facilities. Registers of visitors are kept and sign-in sheets are used in locations that require additional security. All employees are given unique ID photo badges which they are required to wear and clearly display at all times in International SOS facilities.
Information systems containing sensitive information and communications equipment are placed in secure areas and protected by additional physical security measures that permit access only to the employees who need access, operational processes, environmental controls and fire detection and suppression systems to safeguard against accidental loss, theft or unauthorized removal, misuse, damage or unauthorized access.
- Laptops are required to be secured with cables and combination locks.
- Security against unauthorised electronic access and viruses
- All gateways to the internet are protected by a firewall and access to both internal and external networks are restricted and controlled.
- IDS is deployed at key sites.
- All servers are hardened based on security hardening standards to protect against network threats.
- Endpoint security is constantly being review to protect the network against unauthorized access, data loss or destruction.
- Access to computer services and information is on a 'roles and responsibility' basis and is restricted and controlled based on the business requirements to reduce the risks associated with misuse, such as alteration, destruction and unauthorised dissemination of data.
- Access to information services is through a secure login process with a unique identifier.
- Access to and release of voice recordings is subject to review and approval by 3 management levels
- User access to our main case management system and essential network services are controlled using a user rights management system that utilises employees' roles in assigning user access rights, especially to the case management system.
- All remote-s access is given on a needs basis and is via a two-factor authentication mechanism.
- Key personnel laptops have full disk encryption software. The software is configured with a system lock-out feature enabled after a certain number of incorrect password entries.
- Mobile devices have password policy controls and remote device hardware reset features enabled to protect against lost or stolen devices.
- Changes to production systems and network follow a change management process flow to ensure that changes are owner authorized, assessed for risk and operational impacts, before being approved by the change management board.
- The security of information assets, including those entrusted to International SOS by third parties, are audited and reviewed for compliance against company policies and legal requirements. The information security team conducts regular site-level information security audits.
- Critical servers are scanned using network and system vulnerability scanners. Web applications are also scanned by automated penetration tools for application level security vulnerabilities that may be susceptible to hacking.
- External vulnerability scanning on our internet facing sites is performed monthly to ensure that these sites are secure. These are done via in-house vulnerability scanning tools and third party services.
- Penetration tests are also performed on our key internet applications prior to production or major upgrades.
- International SOS engages external consultants to conduct security review of our environment. These reviews help us to understand the security gaps and ensure that our infrastructure and applications are able to meet and mitigate new network and Internet security threats and risks.
11. How do I resolve disputes with International SOS relating to Personal Data?
If you are unsatisfied with the manner in which your question or concern was addressed, in respect of our online services, you may contact International SOS at email@example.com. If you have an unresolved privacy or data use concerns about the online services provided by International SOS Assistance Inc or your use of this website that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
If you do not wish to make a complaint through our online services, you may direct all enquiries, concerns or complaints regarding the collection, use, storage, correction, deletion, blocking, disclosure or transfer of personal data to the Data Protection Administrator who is also the International SOS Country General Manager, in the country in which you reside or are receiving services using the contact details attached to this statement.
If you do not receive a satisfactory response from the Data Protection Administrator you may contact the International SOS Chief Data Protection Officer, who is also the General Counsel of International SOS using the contact details attached to this statement.
The Chief Data Protection Officer has overall responsibility at International SOS for protecting personal data.
International SOS will investigate all concerns and complaints and will address them expeditiously. An acknowledgement of the identity of the employee addressing the complaint and the approximate length of time that will be taken to review the complaint will be provided no later than five (5) business days from the date the complaint is received and understood. Regular updates shall be given to you on the progress of the review if the review is likely to take longer than seven (7) business days.
You have the right at any time, to raise your issues with a data protection authority or to take your case to a court.
If you receive services from International SOS through an employer or through a relative's employer or through an association or institution, or an insurance or financial services program and your personal information has been improperly collected, used, stored, disclosed, amended, destroyed, blocked or transferred as a result of the actions or inactions of the employer, association or institution, insurance company or financial services company, then you will be directed by International SOS to such employer, association or institution, insurance company or financial services company. International SOS will not be liable for resolving disputes between you and such companies, associations or institutions.
12. Changes to this Statement
International SOS reserves the right to change this policy at any time by notifying users through its website of the existence of a new privacy statement prior to the change becoming effective. This statement and the policies outlined herein are not intended to and do not create any contractual or other legal rights. We encourage you to periodically review this page for the latest information on our privacy practices.
Updated: 8 November 2016