Information about the processing of personal data of patients by healthcare facilities

Dear clients,

in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the “General Regulation”), inform you that our healthcare facility GENNET, s.r.o. , with registered office in Prague 7, ID: 27080234, registered in the Commercial Register maintained by the Municipal Court in Prague, Section C, Entry 94758, as a personal data manager (the “administrator”), processes your personal data, and the rights and obligations associated with them.

Personal data is considered to be all information about an identified or identifiable natural person (also referred to as the “data subject”); an identifiable natural person is a natural person that can be identified directly or indirectly, in particular by reference to a particular identifier such as name, identification number, location data, network identifier or one or more specific elements of physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person.

1. Scope and purpose of processing personal data

The administrator processes personal data to the extent to which it was provided to it by the data subject in connection with the conclusion of a health care contract with the administrator or in connection with the provision of health services in accordance with Act No 372/2011, on health services and the conditions of their provision (the Health Services Act), its implementing regulations and other regulations governing the provision of health services. The administrator also processes personal data that was not provided to it by the data subject, but which it obtains in the provision of health services, e.g. as results of specific examinations. The administrator processes personal data in accordance with the valid and generally binding legal regulations of the Czech Republic and to fulfil its legal obligations.

Your personal data is processed for the following purposes:

the provision of health services (the fulfilment of legal obligations by the administrator);
the purpose of negotiating the contractual relationship under consideration (for the purpose of concluding a health care contract);
the purpose following from the performance of a health care contract between you and the administrator;
determination, exercise or defence of legal claims;
to the extent necessary, provision to legal, economic and tax advisors and auditors, for the purpose of providing advisory services to the administrator;
protection of company property and protection of the life, health, property and personal data of patients, employees and other persons present within the premises of the administrator and prevention of undesirable acts and phenomena through camera systems; for detailed information on how to process information via camera systems, see “Information on the processing of personal data through camera systems “;
evaluation of the quality of health services and sending satisfaction questionnaires within it (authorized interest of the administrator).

2. Sources of personal data

The administrator processes personal data it obtains:

in connection with the provision of health services within the meaning of Act No 372/2011 on health services and conditions of their provision, and Act No 373/2011 on specific health services;
directly from data subjects in connection with complaints handling;

3. Categories of personal data and category of data subjects

The following categories of personal data are subject to processing:

address and identification data used to identify clearly and unambiguously data subjects, such as name, surname, date of birth, permanent address and others;
contact details such as contact address, phone number, e-mail address and others;
other data, such as bank details;
data that can be detected from camera records, especially gender and appearance.
other data necessary for the performance of a health care contract, in particular data on the health of the data subject.

The data subjects whose data are processed by the data administrator and to whom this information is addressed are:

client/patient;
potential client/patient;

4. Method of processing and protection of personal data

Personal data is processed in particular in the patient’s medical file in full compliance with applicable laws. Their security and protection is ensured in accordance with these regulations and in accordance with the General Regulation.

Processing is done manually in paper and electronic form or automated by computer technology, subject to all security principles for managing and processing personal data. To this end, technical and organizational measures have been taken by the administrator, in particular those to prevent unauthorized or accidental access to personal data, alteration, destruction or loss, unauthorized transmission, unauthorized processing and other misuse of such personal data. All subjects to whom personal data may be made available respect the rights of data subjects to privacy protection and are required to comply with applicable data protection laws.

5. Period of processing of personal data

The administrator shall process personal data for the time necessary for the fulfilment of the given purpose and in accordance with the time limits specified in the relevant generally binding legal regulations of the Czech Republic for discarding and archiving of documents, or as long as it needs them for the determination, exercise or defence of legal claims.

6. Categories of recipients of personal data

The recipients of personal data of data subjects are:

other health service providers as part of expanding or follow-up health care and providers of selected health services, in particular external laboratories;
public institutions, especially health insurance companies;
on the basis of a contract with the administrator, processors to the extent of data needed for the purpose of processing, e.g. companies managing electronic health records systems, data storage and archiving personnel, and others;
persons providing legal consultancy;
public authorities in the course of fulfilling the legal obligations laid down by the relevant legislation.

7. Lessons learned about the data subject’s rights

As a personal data administrator, you are entitled to do the following in our company:

request access to personal data processed by the administrator, which means the right to obtain from the administrator a confirmation whether the personal data concerning you are processed or not and, if so, you have the right to access these personal data and other information referred to in Article 15 of the General Regulation,
request the correction of personal data processed for you if they are inaccurate. Taking into account the purposes of processing, you may in some cases also request that incomplete personal data be supplemented,
request the deletion of personal data in cases covered by Article 17 of the General Regulation,
request the restriction of personal data processing in cases covered by Article 18 of the General Regulation,
obtain personal data about you that we process in an automated manner to perform a contract concluded with you in a structured, commonly used and machine-readable format, and you have the right to require the administrator to pass this information to another administrator under the conditions and limits set forth in Article 20 of the General Regulation; and
you have the right to object to processing within the meaning of Article 21 of the General Regulation on grounds relating to your particular situation.

If we receive your request, we will inform you about the measures taken without undue delay and, in any case, within one month after the receipt of the request. This time limit can be extended by another two months if necessary and given the complexity and number of requests. In certain cases laid down in the General Regulation, our company is not obliged to comply with the request in whole or in part. This will be the case in particular if the request is clearly unreasonable or disproportionate, in particular because it is repeated. In such cases, we may (i) impose a reasonable fee, taking into account the administrative costs associated with providing the requested information or communication or with making the requested actions, or (ii) refuse to comply with the request.

If we receive the above request, but we will have reasonable doubt as to the identity of the applicant, we may ask him/her to provide the additional information necessary to confirm his/her identity.

In addition, you have the right to contact the Office for Personal Data Protection directly if you believe that personal data are not processed in accordance with legal regulations, in the place of your habitual residence, place of employment, or where there was an alleged violation. If, as a result of the processing of your personal data, you incurred damage other than property damage, a special law applies to the claim.

We also inform you that our company has appointed a Data Protection Officer. Contact details of the Officer: Rita Novoseletska, Na Poříčí 1047/26, 110 00 Praha 1, email: dpo@akdap.cz.

Providing patient’s personal data is a statutory requirement and the patient has an obligation to provide them as well as a healthcare professional has the right to require them. Failure to provide them may mean that the administrator will not be able to provide the patient with a healthcare service, thereby damaging the patient’s health or directly endangering his or her life.