DISCLOSURE TEXT FOR THE PROCESSING OF CLIENT’S AND THE RELATIVES OF THE CLIENTS’ PERSONAL DATA
1- Data Controller
Your personal data is processed by Dr. Şirin Çelik (“Doctor”), located at Teşvikiye Borough, Vali Konağı Street, Inan Apartment Building No:50 Floor:4 Flat No:5, 34365 Şişli/Istanbul as the data controller, within the scope of the Personal Data Protection Law No. 6698 (“KVKK”), the Regulation on Personal Health Data and other relevant legislation provisions, the Ministry of Health of the Republic of Turkey and related authority regulations, and within the framework of this Patient and Patient Relatives Personal Data Processing Disclosure Text (“Disclosure Text”). The corporate ID information of Dr. Şirin Çelik ‘Data Controller” is as follows:
Central Address : Teşvikiye Neighborhood Vali Konağı Street Inan Apartment Building No:50 Floor: 4 Flat No: 5, 34365 Şişli /Istanbul
Phone : +905307858444
Website : https://www.drsirincelik.com/
Email Address : info@drsirincelik.com
Dr. Şirin Çelik adopts the principle of ‘protecting clients’ privacy’ while providing health services, thus respects the rights of both clients and their relatives regarding the privacy and protection of personal data. In line with this, Şirin Çelik processes your personal data in accordance with all the provisions of the legislation on the protection of personal data, especially KVKK, ensures that your data is securely stored and takes all necessary security measures against possible illegal access. This Disclosure Text explains the scope of processing of your personal data collected within the framework of the services provided by our clinic.
2- The Method of Collection of Your Personal Data and the Legal Reasons for the Data Processing
Your personal data can be collected by Dr Şirin Çelik through fully or partially automated means or by non-automatic means provided that it is a part of any data recording system, electronic and/or physical media, patient registration procedures in our practice, printed forms and questionnaires, examinations performed by the doctor, medical tests. Information management system of the Doctor’s office, the website of the Doctor, communication channels, e-mail, telephone, fax, other online and / or offline electronic communication platforms, cargo / mail, within the scope of / examinations and other communications you have with the Doctor and other staff , our social media accounts, the health institutions we cooperate with due to the consultation or the services you receive, and the laboratories we cooperate with and their integrated systems, authorized public institutions and private organizations and their integrated systems and other methods (channels) that may be added to these in the future. Processing by persons or authorized institutions and organizations under the obligation of confidentiality for the purpose of protecting health, performing preventive medicine, medical diagnosis, treatment and care services, planning and managing health services and financing, expressly stipulated in the law, establishment or performance of the contract, legitimate interest, legal obligation, establishment, exercise or protection of a right, your personal data being made public within the framework of your social media accounts, and express consent, if found, are collected within the scope of personal data processing conditions (legal reasons).
3- Your Processed Personal Data Categories and the Purposes of Processing Your Personal Data
Your personal and sensitive personal data data contained in the registration form, especially your health data:
Your identification information(First Name, Last Name, Turkish Identification number or passport number and/or temporary ID number, place and/or date of birth, marital status, gender, health, occupation, insurance card number, place of work, registration and/or patient identification number that can identify you, (with any other identification data)
your contact information (address, telephone number, e-mail address and other communication data and personal data obtained when you contact us via e-mail, letter and/or other means); • Bank account number, IBAN number, credit card information, bills, and billing information, such as financial data; • For the purpose of financing and planning health services, your data on private health insurance and your data on paying institutions such as the Social Security Institution;
All kinds of health information and your data obtained during medical diagnosis, treatment and care services and/or as a result of including but not limited to; patient medical reports, diagnostic data, biometric and genetic information, lab results, test results, examination data, doctor analysis and comments, appointment information, prescription information,
- The record of your call if you have contacted with call center
- The information of your vehicle license plate if you used car parking and valet services
- Your feedback such as survey, letter of thanks, complaint, satisfaction results
Especially your IP address, cookies and other personal data collected during your use of our website and mobile application as well as your mobile data and your personal data given to us with your consent through mobile application including your health data elements comprise your personal data and;
This personal data of yours is recorded within the scope of the Personal Data Protection Law No. 6698 and in accordance with the Regulation on the Processing and Ensuring the Privacy of Personal Health Data, in addition personal data / your personal data can be processed for the purposes indicated in Article 4 relatively and measurably in our archives and can be transferred to persons, institutions and organizations specified in Article 5.
Personal data / Your personal data may be processed for the following purposes:
Identification and identity confirmation in order to prevent personal data / your personal data from being compromised by others, • Maintaining public health, preventive medicine, medical diagnosis, carrying out treatment and care services, management and financing of health services,
Acquisition of medicine and/or medical equipment and/or medical devices specific to you,
To inform you about the appointment, to provide information and / or to remind you of the appointment if you make an appointment • To share and respond to the information obtained with the Ministry of Health, private information management systems associated with the Ministry of Health and other public institutions and organizations in accordance with the legislation,
Sharing and authenticating the information requested by contracted institutions / organizations, especially private insurance companies, within the scope of financing health services (if you have private health insurance AND IF YOU USE PRIVATE HEALTH INSURANCE)
To issue invoice for the services provided,
Analyzing your use of health services and storing your health data, responding to your questions or complaints about our services in order to develop and improve the health services we provide to you
Acquisition of necessary data in accordance with the requests and inspections of regulatory and supervisory authorities and official authorities, • Storing necessary information regarding your health data to comply with relevant legislation,
Conducting special promotional and informational activities for you and ensuring that you benefit, contacting you for informational purposes regarding our services
And without limitation to these, carrying out and improving medical diagnosis, treatment and care services, planning and management of medical services and financing, increasing, researching client satisfaction and related reasons. Personal data / your personal data acquired in accordance with the relevant legislation can be process and transferred to the physical archives or information systems owned by Dr…… or ………. Medical Clinic and can be stored in both digital and physical environments.
4- Transfer of Your Personal Data to Third Parties Residing in the Country and Abroad
Your personal data within the doctor’s office / clinic can only be accessed to the extent necessary to fulfill their duties by our employees who have limited authorized access for the purposes detailed above.
On the other hand, your collected personal data can be clearly stipulated in the laws pursuant to Articles 8 and 9 of the KVKK, legitimate interest, legal obligation, establishment, exercise or protection of a right, protection of public health, preventive medicine, medical diagnosis, treatment and care. Within the scope of the personal data processing conditions (legal reasons) of express consent, in case of processing by persons or authorized institutions and organizations under the obligation of confidentiality, for the purpose of carrying out health services, planning and management of health services and financing:
- The Basic Law No. 3359 of health services, No. 663, and its affiliated institutions on the organization and duties of Ministry of Health Decree Law No. 6698 on personal data protection and privacy regulations and the processing of personal health data about the provision of the person authorized by the provisions of other relevant legislation/institutions and/or organizations;
- Our suppliers, potential suppliers and their employees (e.g. social security, certified public accountants and legal consultants, information technologies and data hosting service providers, platforms where services are received in terms of appointments and interviews) for the purpose of providing products and / or services for the execution of doctor’s office / clinic activities )
- In accordance with the provisions of the relevant legislation, especially the PDPL, the Patient Rights Regulation, the Regulation on Personal Health Data, providing information about the health status of the patient, accompanying the patient, receiving the patient’s personal belongings / medicines, in case of medical necessity, court decision or if the patient / legal heirs allow and to the patient’s family members / relatives, companions, attorney or legal representative and other permitted third parties for the purposes of delivery and payment transactions,
- Insurance for health care services by banks for the implementation of process planning finance and accounting jobs, or negotiated with, or complementary private health insurance companies or contracted agencies and organizations • the doctor’s office/clinic in the scope of services to ensure business continuity in the establishment of associations for the purposes of our business and potential business partners, potential business partners and employees (eg. contracted laboratories and pharmaceutical warehouses),
- To the institutions, other health institutions, doctors and health personnel and domestic / foreign laboratories for the purpose of performing the medical diagnosis and treatment processes in the most accurate way and obtaining consultation,
- To the social media platforms, agencies, press/publication organs and to the people who have access to such content in order to plan or establish corporate communication activities, to publish scientific publications to the extent permitted by the legislation, and
- In order to fulfill the legal obligations of the clinic and to follow up legal affairs, to legally authorized organizations and private individuals (e.g. Republic of Turkey Ministry of Health, Provincial health directorates, other units affiliated to the Ministry of Health, Republic of Turkey Social Security Institution, courts).
- Domestic/foreign organizations and other third parties and their legal representatives, with whom we contractually receive and/or provide services, cooperate with, to carry out our activities and
- The legal representatives from whom we receive consultancy, including the lawyers, consultants, auditors we work with, and the legal representatives we authorize,
- Domestic/foreign organizations and other third parties and their legal representatives, with whom we contractually receive and/or provide services, cooperate with, to carry out our activities and
- Legal representatives you have authorized.
5- Period of Processing of Your Personal Data
Your personal data obtained during our clinical activities are stored and destructed in accordance with the general principles and regulations set forth in the policies and procedures of our clinic regarding the storage and disposal of personal data, which is prepared primarily in accordance with Constitution as well as PDPL (KVKK) the Regulation on the Deletion, Destruction or Anonymization of Personal Data and other relevant legislation.
In the cases, where all of the requirements for the processing of personal data as specified within Article 5 and Article 6 of PDPL cease to be satisfied, your personal data will be destructed. Accordingly, your personal data will continue to be processed during the legal time-out periods following the termination of your relationship with our clinic. If your personal data is processed based on the condition of explicit consent personal data processing, it will be destroyed in the first destruction period if you withdraw your explicit consent. In terms of your requests regarding the destruction of your personal data, we kindly ask you to review the 6th section of this Disclosure Text.
6- Your Rights within the Scope of PDPL
We inform you that, as the owner of personal data, you have the following rights in accordance with Article 11 of the PDPL:
To learn whether your personal data is processed or not,
- To request information whether your personal data is being processed,
- To learn the purpose of the processing of your personal data and whether they are used in accordance with their purpose, • To know the third parties to whom your personal data is transferred in the country or abroad,
- To request correction of your personal data in case of incomplete or incorrect processing and to request notification of the transaction made in this context to the third parties to whom your personal data has been transferred,
- To request the deletion or destruction of your personal data if the reasons requiring its processing are no longer valid even though your personal data were being processed in accordance with the provisions of the law and other relevant laws, to request notifying the third parties to whom your processed personal data transferred if your processed personal data is incomplete or incorrect,
- Objecting to the emergence of a result against the person himself by analyzing your processed data exclusively through automated systems,
- To request the compensation of the damage in case of damage caused due to the unlawful processing of your personal data. In order to exercise your aforementioned rights, you can send your request, which includes the necessary information identifying your identity and your explanations about your right that you request to exercise from the rights specified in Article 11 of the KVKK No. 6698, via a notary public to our address at ……… in the disclosure text; or to our address, personally with documents and information identifying your identity, or by e-mail with secure electronic signature to ……….
- Depending on the nature of your request, your applications will be concluded free of charge as soon as possible and no later than 30 (thirty) days later; however, if the transaction requires additional costs, you may be charged a fee according to the tariff to be determined by the Personal Data Protection Board.
- * Any sensitive personal data (e.g. religion information or blood type information) should not be included in the documents in question.
- To the institutions, other health institutions, doctors and health personnel and domestic / foreign laboratories for the purpose of performing the medical diagnosis and treatment processes in the most accurate way and obtaining consultation,
- To the social media platforms, agencies, press/publication organs and to the people who have access to such content in order to plan or establish corporate communication activities, to publish scientific publications to the extent permitted by the legislation, and
- In order to fulfill the legal obligations of the clinic and to follow up legal affairs, to legally authorized organizations and private individuals (e.g. Republic of Turkey Ministry of Health, Provincial health directorates, other units affiliated to the Ministry of Health, Republic of Turkey Social Security Institution, courts).
- Domestic/foreign organizations and other third parties and their legal representatives, with whom we contractually receive and/or provide services, cooperate with, to carry out our activities and
- The legal representatives from whom we receive consultancy, including the lawyers, consultants, auditors we work with, and the legal representatives we authorize,
- Domestic/foreign organizations and other third parties and their legal representatives, with whom we contractually receive and/or provide services, cooperate with, to carry out our activities and
- Legal representatives you have authorized.
7- Situations in Which Personal Data May be Processed Without Explicit Consent in Accordance with PDPL:
- To the institutions, other health institutions, doctors and health personnel and domestic / foreign laboratories for the purpose of performing the medical diagnosis and treatment processes in the most accurate way and obtaining consultation,
- To the social media platforms, agencies, press/publication organs and to the people who have access to such content in order to plan or establish corporate communication activities, to publish scientific publications to the extent permitted by the legislation, and
- In order to fulfill the legal obligations of the clinic and to follow up legal affairs, to legally authorized organizations and private individuals (e.g. Republic of Turkey Ministry of Health, Provincial health directorates, other units affiliated to the Ministry of Health, Republic of Turkey Social Security Institution, courts).
- Domestic/foreign organizations and other third parties and their legal representatives, with whom we contractually receive and/or provide services, cooperate with, to carry out our activities and
- The legal representatives from whom we receive consultancy, including the lawyers, consultants, auditors we work with, and the legal representatives we authorize,
- Domestic/foreign organizations and other third parties and their legal representatives, with whom we contractually receive and/or provide services, cooperate with, to carry out our activities and
- Legal representatives you have authorized.
- Patient / Patient’s Legal Representative / Patient’s Guardian / Parents of Non-Distinguished Pediatric Patients / Other Patient Relatives
- I have read and accept the entire Disclosure Text above.
………………………………………………………………………………………………………… (Please write ”I have read and understood” with your handwriting)
THE CLIENT’S
FIRST NAME/LAST NAME
SIGNATURE…………………………………………………………………………………………….
This section should be filled in by people other than the patient mentioned above. Name-Surname :
Degree of relationship :
Date :
Signature :