Summary:
- Do we process your personal data? Yes.
- Do we process your private personal data? Yes.
- Do we share? Yes.
- Have we taken adequate security measures? Yes.
- Is there any transfer abroad? Yes, provided that it is limited to foreign patients only.
This clarification text was updated on 5.3.2021. It was issued within the regulations of the principle decisions taken by the Personal Data Protection Board, the law on the Personal Data Protection and the data on our VERBIS registery. Do not forget to visit the Lokman Hekim Esnaf Hospital website for the current version of the Clarification Text, which is periodically updated. Review the Data Inventory to see the department and the processed data map.
- What is the purpose of the Clarification Text?
- In Article 10 of the Personal Data Protection Law, it is regulated that the data subject whose personal data is processed must be informed during the processing of his/her data. In this context, we would like to explain you why we process your personal data.
- This text is very important for you to learn why we process your personal data, to have the opportunity to update your incorrect/incomplete or noncurrent data and to use your rights entitled by the law regarding the protection of personal data. Please read it.
- This text also applies to our former patients.
2. Who Processes Your Personal Data? ( The Data Controller)
LOKMAN HEKIM PRIVATE HEALTH SERVICES INC are responsible for all personal data. The data controller will use the following address and contacts details to use the rights stated in Article 11 of the Personal Data Protection Law.
Address: Tuzla Mahallesi Sadi Pekin Street, 54. Sokak No: 3, 48300 Fethiye,
Contact number: +90 252 612 64 00,
Registered electronic mail (REM): lokmanhekim@hs02.kep.tr,
e-mail address : kvkk@esnafinternational.com
The data controller is registered to the VERBIS (Data Controllers Registry) system.
3. PURPOSES OF PROCESSING YOUR PERSONAL DATA?
We collect and process your personal data in order to:
- initiate and follow-up your treatment,
- carry out private hospital organization process,
- conduct the process in cases where consultation is required,
- carry out the communication process with you,
- make the necessary tests
- carry out maintenance services,
- conduct the medical diagnosis and treatment process in the best way,
- carry on the process to determin your appointment date and time and change requests,
- learn your previous medications and carry out the process of medicine supply .
- conduct accountings and finances processes,
- perform your transfer processes,
- carry out your hospital admission and discharge procedures,
- implement telemedicine services
- register you on Tıp data system,
- send a single use protocol number and verification code to your phone via SMS while processing your appointment,
- carry out surgery and supply processes,
- store and archive health services and financial transactions due to the obligations arising from the legislation,
- perform PCR test and send the results as SMS or code to a communication system chosen by the patient,
- carry out the transport processes of foreign patients and promote health services abroad,
- evaluate the requests and complaints,
- manage the information security processes,
- maintain physical security,
- fulfill all obligations within the scope of personal data protection ,
- send your invoice and test results to a contact address you have chosen
- fulfill the requests of public institutions and organizations,
- follow the feedbacks and contact you,
- carry out your insurance processes,
- conduct the processes of your patient rights,
- follow-up and execute the legal processes,
- provide wireless internet access upon request,
- ensure the use our products and services,
- monitor your medications,
- carry out advertising and promotional activities if you give your explicite consent,
- fulfill the requests of the accommodation facilities within the scope of tourism medicine activities,
- carry out medical examination and health reports processes within the scope of occupational health and safety legislation for employees of the accomodations facilities.
- conduct the ambulance services,
- carry out mobile ambulance and emergency medical services in Dalaman airport area,
- perform home care services,
- follow-up patient relations management processes,
- perform the patient’s outpatient and inpatient treatment procedures,
- effectuate the patient’s vehicle parking procedures
- carry out instant record procedures to Medula system,
- carry out instant record procedures to E-Nabız (E-Pulse) system of the Ministry of Health,
- follow up better your requests
4. WHERE DO WE COLLECT YOUR DATA FROM WITHİN THE SCOPE OF OUR PURPOSE AND WHAT ARE OUR LEGAL REASONS?
We have also included below our methods of collecting your personal data and the legal reasons for our processing purposes. There is a difference in the regulation of the Law on the Protection of Personal Data (article 5 and article 6) among the legal reasons between the processing of sensitive personal data and the processing of your personal data. Your sensitive personal data (such as your health data, sexual life data) will be processed based on more specific processing reasons. Your sensitive personal data is processed only by health professionals and employees under obligation of confidentiality, within the scope of technical and administrative measures that have to be taken in the processing of sensitive personal data.
Your personal data is collected through different means such as our call center or filling out the forms on our website, your application to the front desk, fax, e-mail, face-to-face meeting, the application of the insurances or the contracted accommodation facilities, the patient’s relative or the third party’s application, the notification of the referred hospital, the notification of medical consultants or intermediaries for international patients and the notification of the insurance company of the foreign patient.
Judicial reasons regarding processing are quite important. Processing activities will not take place except for legal reasons, and in some cases, the processing of your personal data will only be based on your explicit consent. You can withdraw the explicit consent you have given at any time but the data processing will still be legal until you withdraw it. Please note that the processing of your personal data is only processed upon your explicit consent, except for legal processing reasons. Please, read in the clarification text the reasons of data processing and make sure you have fully understood.
● Identity Data: Name, Surname, Identity card scan, passport number for foreigners,Turkish identity number, marital status, social security number
- Contact details Data: Telephone number, E-mail address, home address, location data,
- Financial Data: Invoice information, Iban and account number, tax number,
- Patient procedure Data: Call center records, appointment records, patient relatives data, protocol number
- Physical Location Security Data: Camera surveillance recording
- Sensitive Personal Data: Health data (medical diagnosis, treatment, examination data, laboratory results, blood tests, health reports, PCR tests, pregnancy results, MRI results, hospitalisation and discharge data, etc. all medical data, sexual life data, genetic data, vein reading data
- Other data: License plate number
- name-surname, Turkish identity number, passport number for foreigners, address information, e-mail, telephone number, place and date of birth, marital status, gender, social security number, private insurance data, identity scan, plate number, protocol number, financial data (payment, invoicing), laboratory results, camera records, occupation, patient relatives, data of appointment made online on the website, contact details data, call center records data provided that the data of the parties of a contract are directly related to the conclusion or performance of the contract it is mandatory to process the personal data, the fact that the person has made his/her own data public, vein reading, expressly prescribed by laws; this is processed for legal reasons.
● Radiology department, medical units, international patient department, pharmacy, editorial office, VIP patient department, hospitalisation and discharge services department, laboratory unit, doctors, accounting department, medical accounting department, health data provided by the other departments (all treatment data, radiology results, laboratory results, all results based on previous treatment, medication information, health data on the invoice, health reports, pregnancy information, MRI results, tomography results, operating theatre information, patient admission and discharge data), carrying out medical diagnosis, treatment and care services, health services planning and management are processed within the scope of technical and administrative measures that have to be taken in the processing of sensitive personal data (by the persons who are under obligation of confidentiality) based on legal reasons.
- Data such as tax number, social security number, name, surname, address data, Turkish identity number, passport number, credit card, IBAN number, account number processed by the Accounting department being mandatory to the data controller to fulfiil his legal obligations, are processed based on juridical reasons.
- Your audio-visual recordings are processed by the advertising and promotions department if it is necessary within the scope of the legitimate interest of the data controller. The extent of legitimate interest is evaluated very limited, and without the patient’s explicit consent, audio-visual recordings, such as the surgery or treatment was successful cannot be carried out and advertised. If the explicit consent is withdrawn, the record is committed to be removed without delay, as it is stated in the explicit consent text.
- Without your explicit consent your personal data will not be processed for advertising, marketing and promotional purposes (including social media posts), and you will not be contacted on this matter. If you are contacted, please request the removal of the processing. Explicit consents given and obtained via electronic messaging system cannot be accepted as valid in this field as well, seperate explicit consent is needed in this field.
- We re-examined our physical spaces and data processing activities in accordance with the confidentiality rules in the design. Apart from the data that is required to be processed at the request of public institutions and organisations we have minimise our data processing activities as much as possible. When you visit our website, we have taken certain measures to prevent further processing of your data. Please contact us to learn more about these precautions.
5. TO ENSURE PHYSICAL SECURITY, SECURITY CAMERA SYSTEM IS INSTALLED.
In order to ensure physical security, surveillance activities are carried out with a closed circuit camera system outside the private areas of the patient. Provided that it does not affect the fundamental rights and freedoms of individuals It is recorded for a maximum of 90 days for the purpose of physical space security. Security records are only accessed by the IT unit for limited purposes based on the legal reason for the data controller to fulfill its legal obligations if needed.
6. WEB PAGE AND MOBILE APPLICATION ACCESS.
When you visit our website, your personal data such as name-surname, e-mail, phone number are processed on our e-appointment and contact pages. These data are transferred to the screens of the front desk unit and when needed you are contacted.
Your appointment cancellation request is finalized by following the steps on the website.
If you access our website with your mobile telephone, as your location information will be open your location data will then be recorded. We recommend you turn off your location data.
When you visit our website using your laptop or mobile telephone, review your cookie settings and read our cookie policy we published on our website.
3. WE CARRY OUT SOCIAL MEDIA AND ADVERTISING / PROMOTION ACTIVITIES.
We know that this processing activity will never be carried out without your explicit consent. If you give your explicit consent your audio visual recordings such as photos and videos can be processed in our social media accounts. But be aware the processing of your visual and audio recordings poses a risk even though your explicit consent. In the case that your explicit consent is withdrawn, it may be difficult to track the complete removal of this processed data in the event that it is published against our will by third-party applications or other search engines. Make sure that your explicit consent is given entirely of your own free will and that you have read the clarification text well.
Your explicit consent to the message approval we send within the scope of commercial electronic messages is not relevant to this situation, these approvals are recorded separately.
WE PROCESS CHILDREN’S PERSONAL AND PRIVATE DATA
We also share the clarification text regarding the processing of personal data of children up to the age of 16 with their parents, and we take care to ensure that the parents of the children read the text together with the child. We take a high level of precautions regarding the processing and privacy of children’s personal data, and we carry out this process on behalf of the child in a way that ensures his/her privacy. Children’s personal data is never shared on social media and birth photos cannot be used on the hospital’s promotion page.
- WE TRANSFER YOUR PERSONAL DATA.
Your collected personal data is sent to our suppliers, (with your explicit consent) to accommodation facilities and private insurance companies, also to cloud service, accounting program database, public institutions and organizations, police department, database, to the Ministry of Health systems and to the patient’s relative whose name has been previously indicated to us. The foreign patient data are transferred to the foreign insurance company, the hospital abroad and the judicial institutions, with the foreign patien’s explicit consent).
2. OUR APPROACH TO DATA TRANSFER ABROAD
Data on foreign patients are shared by the international patient unit with tour operators, foreign insurance companies, hospital located in the foreign country, with the patient’s explicit consent. Provided that the foreign patient’s explicit consent is provided it is also shared with the other party’s lawyer with whom the patient is in dispute, foreign arbitration and mediation institutions and judicial institutions.
3. WOULD YOU LIKE TO KNOW YOUR RIGHTS AS A DATA SUBJECT?
- to learn whether your personal data are processed or not,
- to request information if your personal data are processed,
- to learn the purpose of your personal data processing and whether they are used for intended purposes,
- to know the third parties to whom your personal data is transferred at home or abroad,
- to request the rectification of the incomplete or inaccurate data, if any
- to request the deletion or destruction of your personal data under the conditions laid down in the Law,
- to request notification to third parties to whom personal data has been transferred in case of incomplete and incorrect processing, deletion or destruction of personal data,
- to object to the processing, exclusively by automatic means, of your personal data, which leads to an unfavourable consequence for the data subject
- to request compensation for the damage arising from the unlawful processing of your personal data
4. CONTACT US
Contact us by filling out the application form on our website www.esnafinternational.com
In order to use the above specified rights, as data subject you shall send a written and wet-signed application with your identity informations to the following adres: LOKMAN HEKİM ESNAF HOSPITAL Tuzla Mahallesi Sadi Pekin Caddesi, 54. Sokak No: 3, 48300 Fethiye / MUĞLA (DATA CONTROLLER), or an email (using a registered electronic mail address previously specified to the data controller) either with secure electronic signature or mobile signature to lokmanhekim@hs02.kep.tr, stating explicitely the right to which you are applying.
The applications should be solely yours. For the applications to be made on behalf of someone else, your legal documents stating that you represent the applicant must be attached to the application letter. Within this scope, The Data Controller shall reply you within the latest 30 days. The applications are completely free of charge, but if the procedure requires additional cost, the prices determined by the Personal Data Protection Board may be applied and requested. You can visit www.kvkk.org.tr address to get more informations about the current prices. Complaints made to the Personal Data Protection Board shall not be taken in consideration. Complaints made direct to the Personal Data Protection Board will not be considered without prior application to the data controller. (Please visit https://esnafinternational.com/://sikayet.kvkk.gov.tr