This quality policy applies to the processing of personal data by Stichting Acibadem IMC, having its registered office in Amsterdam and having its registered office at Arlandaweg 100, 1043HP Amsterdam and registered in the register of the Chamber of Commerce under number 62665618, hereinafter referred to as Acibadem IMC. (Last edited 1th October 2020)

1.Processing of personal data by Acibadem IMC

The protection of personal data is very important to Acibadem IMC. Acibadem IMC respects your privacy and ensures that your personal information is always treated confidentially and in accordance with applicable privacy legislation. Acibadem IMC processes your personal data for the following processes:

• Delivering care.
• The exchange of healthcare information for chain care or collaboration.
• Performing activities to support business operations.
• Giving and receiving education.
• Management and accountability.
• By personal data we mean the information that can be traced to a natural person, for example a name, a home address or an email address.

2. Processing purposes

Your personal data is processed by Acibadem IMC for the following purposes:

• Maintaining and supporting adequate treatment and care for patients, for which good quality of care is guaranteed as much as possible.
• Timely communication with external care providers from the care chain.
• Adequate and efficient operational management.
  Education with the aim of increasing the quality of care and management by well-trained employees and care providers.
• Conducting (scientific) research.
• Management and accountability with the aim of increasing the quality of care, efficient operational management and financial, policy and process accountability.

3. Foundations for the processing of your personal data

• The processing activity is always based on one of the following principles:
• The permission you have given (article 6, paragraph 1, sub a, AVG).
• Taking pre-contractual measures at your request and / or the implementation of the agreement entered into with you (Article 6, paragraph 1, sub b of the GMS).
• Complying with legal obligations (Article 6, paragraph 1, sub c of the GDPR).
• Protecting vital interests of yourself or others (article 6 paragraph 1 sub d AVG).
• The fulfillment of a task in the public interest or a task in the context of the performance of the public authority (Article 6, paragraph 1, sub e of the GMS).
• The representation of legitimate interests of Acibadem IMC or of a third party (Article 6, paragraph 1, sub f of the AVG), as a good counselor or employer / client or to guarantee the quality and safety of our care and services.

4. Processing of special categories of personal data

Data concerning your health, hereditary data (genetic data) or sexual behavior or sexual orientation are only processed insofar as this is necessary for the proper treatment or care of you as a patient of Acibadem IMC. We only process data about your religious or philosophical beliefs at your own request, with a view to your treatment or care within our institution.

If you work for or within Acibadem IMC, we process information about your health to the extent that this is necessary for obligations under legislation and regulations or from the care of a good employer / client. We only process data about membership of a trade union at your own request.

The data is only processed by persons who are required to maintain confidentiality. All persons working within or on behalf of Acibadem IMC have signed a confidentiality agreement.

5. Information about data processing

When we ask for personal data, we will state for each situation whether the provision of the data is necessary or mandatory and what the (possible) consequences are if the data is not provided. The starting point is always that Acibadem IMC will not process more personal data than is necessary for the purposes described above.

6. Exchange of information

Acibadem IMC only provides personal data to third parties if there is a legal basis, agreement or permission from you as a data subject.

7. Transfer abroad

Your personal data can, on behalf of Acibadem IMC, be processed within countries of the European Economic Area (EEA). There is no processing of your personal data outside the EEA.

8. Automated decision making

Acibadem IMC does not use automated decision making and / or profiling. This means that the assessment of the processed data is always done by a person.

9. Retention period

Acibadem IMC does not store your personal data for longer than is necessary for the realization of the processing purposes described above, unless the storage of this data is necessary to comply with a legal obligation.

10. Security of your personal data

Acibadem IMC takes appropriate technical and organizational measures to protect your personal data against loss or any form of unlawful processing. We ensure appropriate security, in line with the applicable legal requirements and guidelines. Various measures have been taken in that context, including encryption of data, encrypted communication, access control and treatment of the data as being confidential. Persons who have access to your data on behalf of Acibadem IMC are bound by confidentiality. Acibadem IMC requires the same technical and organizational measures from its processors and has recorded this in processing agreements.

11. Your rights

You have various rights under the law. We list these rights for you:

• Right of inspection
• You have the right to view your personal data and to receive a copy at your request.
• Correction and removal right / right to oblivion
• You have the right to supplement, change or even delete your data if the data is not (any longer) correct, or if the processing is not (no longer) justified.
• Right of objection
  The right of objection means that you can object to certain processing of your personal data because of your specific situation. You only have this right with regard to all processing operations that are not based on your consent, taking pre-contractual measures at your request and / or the execution of the agreement concluded with you, complying with legal obligations or protecting vital interests of yourself or others.
  If you object to the use of your personal data to inform you about activities of Acibadem IMC and similar (“direct marketing”) processing, we will always honor this objection. Your data will then no longer be used for (direct) marketing purposes.
• Right to restriction
  Under certain circumstances you also have the right to limit the processing of your data. In short, this means that Acibadem IMC temporarily “freezes” the processing of your data. You can invoke this right in four situations:
  • Pending the assessment of a correction request.
  • If data should actually be deleted, but you do not want deletion.
  • If Acibadem IMC no longer needs the data while you do need it for (the preparation for) a lawsuit.
  • Pending the assessment of an objection.
• Right to data transferability (data portability)
  You have the right to (re) receive the data you provide to Acibadem IMC in a standard file format. This right only applies to the personal data that we process about you on the basis of your consent or an agreement concluded with you.
  The right to transferability applies to part of the data in medical records. The personal data that you have actively and intentionally provided is subject to the right to transferability. This also applies to the data that you have provided indirectly through the use of a service or device. For example, the data that a pacemaker or blood pressure monitor generates.
  The data in the medical file that you have not provided directly or indirectly through the use of a service or device are not covered by the right to transferability. The right to transferability does not apply, for example, to the conclusions, diagnoses, suspicions or treatment plans that the treating physician establishes on the basis of the data provided by you as a patient.
• Withdrawal of permission
  For data that we process on the basis of your consent, you have the right to withdraw your consent at any time. We will immediately stop processing. Withdrawing the permission has no retroactive effect; all processing that has already taken place therefore remains lawful.
• Exercise of your rights
  Exercising your rights is free of charge for you, except for abuse. You exercise the rights by contacting us via the contact details below.
• Terms
  We will in principle answer your questions / requests within one month. In the unlikely event that it takes more time to answer your question / request, we will inform you about this within one month. Due to the complexity of the requests and / or the number of requests, it may be that the total response time runs up to three months.
• Identification
  For all questions / requests we can ask for further proof of your identity. We do this to prevent us from providing personal data to the wrong party or making unjustified changes to the personal data or the way in which we process that personal data.
  The copy of your proof of identity will only be used to establish your identity and will be destroyed immediately after it has been established.
• Individual consideration for every request
  We would like to point out that the rights described above are not absolute rights. There may be circumstances that prevent us from responding to a specific request. We will always assess each request on its own merits. Should we still not be able to respond to a specific request, we will of course make this known to you with motivation.

12. Data Protection Officer

Acibadem IMC has appointed a Data Protection Officer (FG). The FG supervises compliance with privacy legislation and advises within Acibadem IMC on the application of privacy legislation.

The FG is independent and enjoys legal dismissal protection. The FG reports directly to the Board of Directors of Acibadem IMC. The FG is also the contact person for all questions about privacy, both for you and the person concerned and for the regulator. You can contact the FG via fg@acibademimc.com

13. Supervisor

The Dutch Data Protection Authority is the regulator of privacy legislation in the Netherlands. Do you have questions or complaints that you do not want or cannot discuss with Acibadem IMC? Then contact the Dutch Data Protection Authority via the website www.autoriteit Individual Data.nl.

14. Changes

This privacy statement can be changed. These changes will be announced on the Acibadem IMC website.

15. Questions & contact

You are of course free to ask questions regarding the processing of your personal data within Acibadem IMC. If you have any questions about this privacy statement, or wish to invoke one of your legal privacy rights or wish to make a complaint regarding privacy, you can contact the Data Protection Officer: fg@acibademimc.com