Our policies

Aspen Medical UAE vision is to be the leading global health services provider.

To ensure the effectiveness of the Quality Policy, Aspen Medical UAE shall ensure the quality management system is planned, implemented, reviewed, and improved, considering the organisation works within a risk management framework.

Aspen Medical UAE has three (3) core principles that govern the company’s operations:

• High Quality Service Delivery
• Excellence in Human Resources
• Sound Financial Management

Aspen Medical UAE is committed to:

• providing quality services and all applicable ISO 9001:2015 requirements and UAE sector regulatory authority requirements.
• considering and meeting any external and internal issues relevant to our purpose, strategic direction that affects our Quality Management System in achieving its intended results.
• determining and meeting the requirements of relevant stakeholders.
• complying with statutory and regulatory obligations, standards, specifications, and relevant codes of practice.
• continually improving our Quality Management System by ensuring operational efficiencies, clinical governance, and enhancing customer satisfaction.

Aspen Medical UAE shall ensure that the Quality Policy shall be published through the intranet and communicated to all employees, patients, visitors, contractors through notice board and by placing the policy portraits at all the prominent places of each entity.

Aspen Medical is committed to safeguarding the health, safety, and wellbeing of our people, our patients, our partners, our clients, and the communities in which we operate. Health, safety, and environmental sustainability (HSES) is fundamental to the way we operate. People are at the heart of our capacity to be the preferred provider of outsourced health services wherever we are needed

Aspen Medical believes all incidents are preventable; as a result, our objective is to strive for zero harm by ensuring we have safe people, safe workplaces, and safe work practices.

Aspen Medical will:

• uphold our value of a genuine commitment to ensure the health and safety of our people and to protect the environment from harm,
• establish clear leadership responsibilities for HSES,
• comply with all relevant legislation, policies, procedures, license conditions and other relevant requirements, and where appropriate go beyond compliance to achieve the aims of this policy
• implement policies and procedures with training in accordance with our accredited management systems (ISO 9001, ISO 45001, and ISO 14001), OSHAD SF (Version 3.1, Mar 2017), HAAD standards for Environmental, Health & Safety Management System, applicable UAE local associated regulations, that are appropriate for our operations,
• on client-controlled sites, comply with the contract and their HSE Management Systems requirements,
• incorporate an attitude of environmental stewardship throughout the organization
• identify, assess, and manage risks to prevent injuries or illnesses to our people and harm to the environment, including the efficient use of all-natural resources,
• communicate openly with staff, encouraging initiatives through consultation that contribute to a safer, healthier, and environmentally sustainable working environment,
• report and investigate all injuries, illnesses, near misses and environmental incidents,
• provide effective support and return to work programs when staff are injured at work,
• seek ways to promote and improve the health and wellbeing of our people,
• establish and achieve challenging HSES goals,
• inspect, audit, and review our behaviors, systems of work and workplaces to learn and seek continuous improvement in how we operate,
• measure, evaluate and report our performance progress against set targets and key performance indicators, and
• respect the traditional rights and culture of Indigenous people wherever we work.
• this HSES policy shall be reviewed every two years to keep it in line with changes in current legislator, target and objectives.
• this policy shall be published through the intranet and communicated to all employees, patients, visitors, clients, contractors through notice board and by placing the policy portraits at all the prominent places of the premises.

1. Purpose

Consistent information security risk management is important for Aspen Medical UAE, its customers and stakeholders. This policy demonstrates Aspen Medical UAE’s commitment to information security and communicates our vision of information security.

2. We commit to:

• Managing information assets in an accountable and coordinated manner in accordance with legislative and contractual requirements and principles of good governance.
• Protecting the integrity of all information disseminated, produced, managed, or stored.
• Handling information, whether Aspen Medical or customer-owned, through sound information security procedures to protect all information assets for internal, external, deliberate, or accidental threats.
• Drive information security through risk-based information security principles by implementing an Information Security Management System (ISMS) aligned to ISO / IEC 27001: 2022.

3. We will achieve this by living our information security principles:

TRUSTWORTHY

• Embedding a culture of accountability and responsibility for the confidentiality, integrity, availability, safety and reliability of Aspen Medical UAE’s information assets and systems
• Enabling our people to take accountability for their use of information in their day-to-day role.
• Integrating information security risk management principles into our planning and decision-making.

TRANSPARENT

• Engaging with the business to garner feedback on our ISMS and cyber security program.
• Providing engaging and right information security training across Aspen Medical UAE to ensure an understanding of the requirements of Aspen Medical UAE’s approach to information security.
• Providing clear and direct guidance on our expectations for the protection of all information, including internal, third party, personal and electronic data.

PRIVATE

• Understanding the root causes of cyber security events and incidents without allocating blame or assigning punishment.
• Understanding our cyber security objectives and legislative and contractual environment to ensure it is accurately represented within our information security policy framework.
• Empowering our people to take responsibility in our cyber secure culture and report any concerns or risky behaviours they witness.

VALUED

• Proactively measuring our ISMS to enable reporting of the right information to the right people.
• Critically reviewing our ISMS to find positive ways of continually improving and developing it.
• Creating innovative ways of communicating our commitment and leadership in information security within our community and industry.

4. Accountability and responsibility

• Aspen Medical UAE (United Arab Emirates) Board is accountable for ensuring sufficient resourcing, management, and monitoring of the ISMS.
• The Executive General Manager is responsible for leading the implementation and compliance with the ISMS, including communicating Aspen Medical UAE’s vision of information security and its importance.
• All executives, managers, employees, and contractors must adhere to this policy and act in a manner that continually promotes a cyber-secured culture and the management of information security risk.

This website, www.aspenmedical.ae (Website), is owned and operated by Aspen Medical, located at Al Nasr Street, Al Badi Tower, Level 2 Abu Dhabi, United Arab Emirates. This policy covers the Aspen Medical (Aspen Medical, us, our, we), which includes:

Aspen Medical Assistance LLC (CN -1099714)

Aspen Medical Services LLC -Sole Proprietorship LLC (CN -3773743)

Uniteam Primary Health Care Center LLC (CN 2893674)

Uniteam Primary Health Care Center LLC (CN 2894022)

Uniteam Primary Health Care Center LLC (CN 2828657)

Uniteam Primary Health Care Center LLC (CN 2908721)

Uniteam Primary Health Care Center LLC (CN 2893652)

Uniteam Primary Health Care Center LLC (CN 2894056

Access to and use of our Website, and any products, services, content and information available through our Website (collectively, Services) are subject to the following terms, conditions and notices (Terms of Use). By using the Services, you are agreeing to all of the Terms of Use, as may be updated by us from time to time. You should check this page regularly to take notice of any changes we may have made to the Terms of Use.

1 Amendments to Terms of Use

We reserve the right to amend these Terms of Use from time to time. Amendments will be effective immediately upon notification on our Website. Your continued use of our Website following such notification will represent an agreement by you to be bound by the terms and conditions as amended.

2 Website Access and Online Accounts

1. Access to our Website, including any online account you register for, is permitted on a temporary basis, and we reserve the right to withdraw or amend the Services without notice. We will not be liable if for any reason our Website is unavailable at any time or for any period. From time to time, we may restrict access to some parts or all of our Website
2. When you register for an online account via our Website, you will set up a personal login containing your email address and password of your choice. You must not share these login details with anyone else or allow others to use and access your account.
3. You may upload content via your account including your image, and other information about you. You acknowledge and accept that any information you upload will be published and available in your online account.

3 Linked Sites

This Website may contain links to other websites (Linked Sites), which are not operated by Aspen Medical. Aspen Medical has no control over the Linked Sites and accepts no responsibility for them or for any loss or damage that may arise from your use of them. Your use of the Linked Sites will be subject to the Terms of Use and service contained within each Linked Site.

4 Our Information Policies

Information about how we collect, use, store and protect your information can be found in our Website Privacy Policy, Information Security Policy, and Personal Information Collection Notice. By using our Website, you consent to the collection and processing of your information as described in these policies and warrant that all data provided by you is accurate.

If you have any further questions regarding your personal information, you can contact us at privacy@aspenmedical.ae

5 Prohibitions

You must not misuse our Website. You will not:

1. commit or encourage a criminal offence;
2. transmit or distribute a virus, trojan, worm, logic bomb or any other material that is malicious, technologically harmful, in breach of confidence or in any way offensive or obscene;
3. hack into any aspect of the Service; corrupt data; cause annoyance to other users;
4. infringe upon the rights of any other person’s proprietary rights;
5. send any unsolicited advertising or promotional material, commonly referred to as “spam”;
6. attempt to affect the performance or functionality of any computer facilities of or accessed through our Website.

Breaching this provision would constitute a criminal offence and we will report any such breach to the relevant law enforcement authorities and disclose your identity to them.

We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our Website or to your downloading of any material posted on it, or on any Linked Sites.

6 Intellectual property, software and content

The intellectual property rights in all software and content (including photographic images) made available to you on or through our Website remain the property of Aspen Medical or its licensors and are protected by copyright laws and treaties around the world. All such rights are reserved by Aspen Medical and its licensors. You may store, print and display the content supplied solely for your own personal use. You are not permitted to publish, manipulate, distribute or otherwise reproduce, in any format, any of the content or copies of the content supplied to you or which appears on our Website, nor may you use any such content in connection with any business or commercial enterprise.

7 Disclaimer of liability

1. You use our Website, at your own risk. To the extent permitted by law, our Website is provided to you on an “as is” and “as available” basis without guarantee or warranty of any kind (express or implied).
2. Whilst reasonable attempts are made to ensure the accuracy of the content on our Website, this is not always possible, and content may not be true, accurate, up-to-date or complete. Aspen Medical does not invite reliance upon and does not accept responsibility or liability for any content made available on our Website.
3. To the fullest extent permitted by law, you unconditionally release Aspen Medical, its officers, employees, contractors, volunteers, stakeholders, representatives and agents from all liabilities, actions, demands, loss, damage, costs and expenses (including legal costs on a full indemnity basis) and, including but without limitation to any direct, indirect, special, consequential, punitive or incidental damages, or damages for loss of use, profits, data or other intangibles, damage to goodwill or reputation, or the cost of procurement of substitute goods and services, incurred or suffered by you directly or indirectly in connection with your access to, or use of, inability to use, or any performance or failures of this Website or the Linked Sites and any materials posted on those sites, irrespective of whether such damages were foreseeable or arise in contract, tort, equity, restitution,
4. This does not affect Aspen Medical’s liability for death or personal injury arising from its negligence, fraudulent misrepresentation, misrepresentation as to a fundamental matter or any other liability that cannot be excluded or limited under applicable law.

8 Disclaimer as to ownership of third-party trademarks, images of personalities and content

Except where expressly stated to the contrary all persons (including their names and images), third-party trademarks and content, services and/or locations featured on our Website are in no way associated, linked or affiliated with Aspen Medical and you should not rely on the existence of such a connection or affiliation. Any trademarks/names featured on our Website are owned by the respective trademark owners. Where a third-party trademark or brand name is referred to, it is used solely to describe or identify the products and services and is in no way an assertion that such products or services are endorsed by or connected to Aspen Medical.

9 Linking to our Website

You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it, but you must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists. You must not establish a link from any website that is not owned by you. This Website must not be framed on any other site, nor may you create a link to any part of our Website other than the home page. We reserve the right to withdraw linking permission without notice.

10 Indemnity

You agree to indemnify, defend and hold harmless Aspen Medical, its directors, officers, employees, consultants, agents, and affiliates, from any and all third-party claims, liability, damages or costs (including, but not limited to, legal fees) arising from your use of our Website including all content and intellectual property made available to you on our Website, or your breach of the Terms of Use.

11 Variation

Aspen Medical has the right to, at its absolute discretion, at any time, and without notice to amend, remove or vary the Services or any page of our Website.

12 Invalidity

If any part of the Terms of Use is unenforceable (including any provision in which we exclude our liability to you) the enforceability of any other part of the Terms of Use will not be affected and all other clauses remain in full force and effect. So far as possible where any clause or part of a clause can be severed to render the remaining part valid, the clause must be interpreted accordingly. Alternatively, you agree that
the clause must be rectified and interpreted in such a way that closely resembles the original meaning of the clause as is permitted by law.

13 Questions or Complaints

We will try to answer your questions and resolve issues when they first arise. Please let us know if you have any questions, comments, or concerns by first contacting us privacy@aspenmedical.ae

This privacy notice tells you about the information we collect when you use our website.

In collecting this information, we are acting as a data controller and, by law, we are required to provide you with information about us, about why and how we use your data, and about the rights you have over your data.

Aspen Medical is committed to complying with the Abu Dhabi Health Information Cyber Security Standards (ADHICS, and other applicable privacy and data protection legislation, including the European Union’s General Data Protection Regulation (GDPR).

The GDPR is the European regulation governing the handling of personal information about individuals. This is applicable to individuals within the European Union. Aspen Medical complies with the Act and the GDPR in its dealings with the personal information of individuals. Aspen Medical collects personal information from individuals using fair and lawful means in the course of its business and the care of patients. It collects this information so that it can conduct its business and provide the best possible care to patients.

Who are we?

Aspen Medical Assistance LLC and Uniteam Primary Health Care Center LLC are United Arab Emirates (UAE) registered businesses operating under Aspen Medical. Our head office is located at Al Nasr Street, Al Badi Tower, Level 2 Abu Dhabi, United Arab Emirates. You can contact us by email at privacy@aspenmedical.ae or by telephone on 02 208 7000.

This policy covers the Aspen Medical (Aspen Medical, us, our, we), which includes:

Aspen Medical Assistance LLC (CN -1099714)
Aspen Medical Services LLC -Sole Proprietorship LLC (CN -3773743)
Uniteam Primary Health Care Center LLC (CN 2893674)
Uniteam Primary Health Care Center LLC (CN 2894022)
Uniteam Primary Health Care Center LLC (CN 2828657)
Uniteam Primary Health Care Center LLC (CN 2908721)
Uniteam Primary Health Care Center LLC (CN 2893652)
Uniteam Primary Health Care Center LLC (CN 2894056)

How do we use your information?

• When you use our website
• When you submit an enquiry via our website
• When you are a patient
• When you apply for a position on our website
• To send direct marketing communications about Aspen Medical’s products, services, offers, company news, events, surveys, or other documentation
• To update you on your rights as a data subject
• To update you on your right to complain
• To provide you updates to this privacy policy.

When you use our website

When you use our website to browse our products and services and view the information, we make available, a number of cookies are used by us and by third parties to allow the website to function, to collect useful information about visitors and to help to make your user experience better.

Some of the cookies we use are strictly necessary for our website to function.

Strictly necessary cookies

Strictly necessary cookies are essential to enable you to navigate around our website and use its core features. Without these cookies, services such as remembering your login details or ensuring what you see looks correct on the device you are using would not be possible. These cookies do not gather information about you that could be used for marketing and do not track your internet usage.

Preference cookies

Preference cookies enable the website to adapt to the user’s website template design, by gathering information such as the user’s preferred language or region.

Statistical and performance cookies

These cookies help us understand how you interact with our website by collecting and reporting information about your journey on our website. For example, they help us understand which pages you go to most often, how much time you spend on which pages, which links you choose to click and the journey you took during the website session.

When you submit your enquiry to our website

Submitted data

When you submit an enquiry via our website or other electronic means, we may ask you for your personal data.

We use this information to respond to your query, including providing you with any requested information about our products and services. We may also email you several times after your enquiry in order to follow up on your interest and ensure that we have answered your query to your satisfaction. We will do this based on our legitimate interest in providing accurate information.

We will also use this information to contact you for direct marketing purposes. We retain this information until you opt out or withdraw your consent.

Your enquiry is stored and processed as an email that is hosted by Microsoft in the region you have selected. We do not use the information you provide to make any automated decisions that might affect you. You can request Aspen Medical to delete any enquiry emails.

When you are a patient

Where you are a patient and we are providing you with medical treatment, we will collect personal information including demographic information (such as name, date of birth and address), health history, family history, ethnic background, and current lifestyle. We will collect this information directly from you. We may collect personal information about patients from other sources, but only where required and permitted by law, for example in a medical emergency.

We use this information to diagnose and treat your condition. If you fail to provide this information, we may not be able to provide appropriate healthcare. We may also use this information for the purposes of quality assurance, accreditation and audit activities, risk and claims management, patient satisfaction surveys and staff training and education. Where possible, we will de-identify this personal information where we use it for these purposes.

We will only disclose the personal information of patients to third parties with the consent of the patient, or as otherwise permitted by Abu Dhabi Health Information Cyber Security Standards (ADHICS) applicable to the circumstances. We do not send personal information to third parties without prior authorization and does not share patient information cross borders.

The personal information of patients is stored securely using physical means such as locks and restricted premises and by electronic methods including passwords and secure servers located in UAE in compliance with Abu Dhabi Health Information Cyber Security Standards (ADHICS). We take reasonable steps to prevent loss, theft, misuse and interference of personal information, and we have policies and procedures in place to protect this information.

When you apply for a position via our website

When you apply for a position via our website, we ask you for your name, email address, phone, email and resume with other relevant information, including employment history and qualifications. We will generally collect this information from you, but we may also collect it from other sources, including previous employers, public domain, and social media websites.

We use this information to process your application. Our Culture and Performance team may also email or phone you several times after your enquiry to follow up on your interest and ensure that we have answered you to your satisfaction. We will do this based on our legitimate interest in providing accurate information. If you fail to provide this information, we may not be able to process your application.

We will only disclose the personal information of job applicants overseas with the applicant’s consent. Where an applicant has completed paperwork for an overseas work permit or other authorization, we deem this to be consent to release the paperwork to the overseas recipient named in the paperwork.

Your enquiry is stored and processed as an email which is hosted by Microsoft in the UAE. Your details will also be stored on our CRM which is managed on an Aspen Medical server within the UAE.

We do not use the information you provide to make any automated decisions that might affect you. We keep applicant details for seven years, after which they are deleted off the CRM. CRM records are kept for seven years after the last contact with you.

European Union GDPR

By law, you can ask us what information we hold about you, and you may request corrections to any inaccuracies. If we have asked for your consent to process your personal data, you may withdraw that consent at any time. You may withdraw your consent by contacting us by email at privacy@aspenmedical.ae

Where you have withdrawn your consent to our processing of your personal data, we will cease to process that information, though your withdrawal of consent does not affect the lawfulness of our actions before you withdraw your consent. Additionally, where our processing is based on the performance of our obligations under a contract, for example, your employment contract, then we may continue processing in accordance with those obligations.

If we are processing your personal data for reasons of consent or to fulfil a contract, you can ask us to give you a copy of the information in a machine-readable format so that you can transfer it to another provider. If we are processing your personal data for reasons of consent or legitimate interest, you can request that your data be erased.

You have the right to ask us to stop using your information for a period of time if you believe we are not doing so lawfully.

Finally, in some circumstances, you can ask us not to reach decisions affecting you using automated processing or profiling. To submit a request regarding your personal data by email, or telephone, either under the Personal Data Protection Law in UAE or the European Union GDPR, please use the contact information provided above in the Who Are We section of this policy.

Applicable law

Excluding third-party links or websites, our website is controlled and maintained in the UAE by Aspen Medical. The courts will determine if any disputes are within the jurisdiction of laws in force in the UAE. If found within the jurisdiction, you must submit and comply with these laws.

Content on this website may not comply with the laws of any country outside of the UAE. If accessing this website outside of the UAE, you do so at your own risk. You accept responsibility to ensure compliance with the laws that apply to accessing, dealing with or actioning transactions with us.

Your right to complain

If you have a complaint about our use of your information, we prefer you to raise in with us in the first instance at privacy@aspenmedical.ae to give us the opportunity to put it right. We will review all complaints received and our Privacy Team will respond to you as soon as is practicable. VeraSafe has been appointed as Aspen Medical Group representative in the United Kingdom for data protection matters, pursuant to Article 27 of the United Kingdom General Data Protection Regulation; and European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union.

If you are located within the United Kingdom or, within the European Economic Area, VeraSafe can be contacted in addition to privacy@aspenmedical.ae, only on matters related to the processing of personal data.

To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/publicresources/contact-data-protection-representative Alternatively, VeraSafe can be contacted at:

VeraSafe United Kingdom Ltd. 37 Albert Embankment London SE1 7TL United Kingdom or via telephone at: +44 (20) 4532 2003.

VeraSafe Ireland Ltd. Unit 3D North Point House North Point Business Park New Mallow Road Cork T23AT2P Ireland +420 228 881 031.

If you are not satisfied with our response, you can also contact the following government organizations:

The European Data Protection Supervisor

Postal address: Rue Wiertz 60, B-1047 Brussels

Office address: Rue Montoyer 30, B-1000 Brussels

Telephone: +32 2 283 19 00

Email: edps@edps.europa.eu

Website: www.edps.europa.eu

Updates to this privacy policy

We regularly review and, if appropriate, update this privacy policy from time to time, and as our services and use of personal data evolves. If we want to make use of your personal data in a way that we haven’t previously identified, we will contact you to provide information about this and, if necessary, to ask for your consent. We will update the version number and date of this document each time it is changed

Consistent information security risk management is important for Aspen Medical, its customers and stakeholders.

This policy demonstrates Aspen Medical’s commitment to information security and communicates our vision of information security.

We commit to:

• Managing information assets in an accountable and coordinated manner in accordance with legislative and contractual requirements and principles of good governance.
• Protecting the integrity of all information disseminated, produced, managed, or stored.
• Handling information, whether Aspen Medical or customer-owned, through sound information security procedures to protect all information assets for internal, external, deliberate, or accidental threats.
• Drive information security through risk-based information security principles by implementing an Information Security Management System (ISMS) aligned to ISO / IEC 27001: 2022.

We will achieve this by living our information security principles:

Information Security Principles

TRUSTWORTHY

• Embedding a culture of accountability and responsibility for the confidentiality, integrity, availability, safety and reliability of Aspen Medical’s information assets and systems
• Enabling our people to take accountability for their use of information in their day-to-day role.
• Integrating information security risk management principles into our planning and decision-making.

TRANSPARENT

• Engaging with the business to garner feedback on our ISMS and cyber security program.
• Providing engaging and right information security training across Aspen Medical to ensure an understanding of the requirements of Aspen Medical’s approach to information security.
• Providing clear and direct guidance on our expectations for the protection of all information, including internal, third party, personal and electronic data.

PRIVATE

• Understanding the root causes of cyber security events and incidents without allocating blame or assigning punishment.
• Understanding our cyber security objectives and legislative and contractual environment to ensure it is accurately represented within our information security policy framework.
• Empowering our people to take responsibility in our cyber secure culture and report any concerns or risky behaviors they witness.

VALUED

• Proactively measuring our ISMS to enable reporting of the right information to the right people.
• Critically reviewing our ISMS to find positive ways of continually improving and developing it.
• Creating innovative ways of communicating our commitment and leadership in information security within our community and industry.

Accountability and responsibility

• Aspen Medical United Arab Emirates (UAE) Board is accountable for ensuring sufficient resourcing, management, and monitoring of the ISMS.
• The Executive General Manager is responsible for leading the implementation and compliance with the ISMS, including communicating Aspen Medical’s vision of information security and its importance.
• All executives, managers, employees, and contractors must adhere to this policy and act in a manner that continually promotes a cyber-secured culture and the management of information security risk.

Why do we collect your information?

We collect your personal information to enable us to send communications, provide feedback or consider your suitability for potential job opportunities that you (or a person/company with whom you
are associated) acquire or wish to acquire.

What happens if you don’t provide the information?

Without your personal information, we may not be able to supply those services, or we may be restricted in the way those services can supplied.

Who might we share your personal information with?

Your personal information will not be shared with anyone else unless it is needed in connection with our ongoing supply of services to you and for purposes associated with the supply of those services. We may share your information because we are required to do so by law.

Will any of your information be shared with overseas organizations?

We operate both in the United Arab Emirates (UAE) and overseas. Therefore, we may need to share some of your personal information with organizations outside the UAE, for example when a person is deployed to an overseas location. We may also store your information in cloud or other types of networked or electronic storage. For further information, please refer to our privacy policy.

How can you access your personal information or make a complaint?

Our website privacy policy contains information about how you may access your personal information and seek correction of such information; as well as how to complain about a breach to Abu Dhabi Health Information Cyber Security Standards (ADHICS) and Global Data Regulation Protection (GDPR) and how we will deal with such a complaint.

View our website privacy policy for full details