REGARDING THE PROCESSING/PROTECTION OF PERSONAL DATA
CLARIFICATION TEXT
INTERNATIONAL POLYCLINIC AND HEALTH SERVICES CORPORATION ( Özel SRK ) places great importance on ensuring that all general and specific personal data belonging to all individuals, particularly our valued patients who have chosen us, is processed and stored in compliance with the Personal Data Protection Law No. 6698 (the Law). In order to provide our services, we may need to collect your personal information and health data, and we may need to record and store such information within the limits required by the service to be provided.
Within the scope of this responsibility, our company, as the "Data Controller" defined in the Law, will be able to obtain, record, store, preserve, update, modify, reorganize, transfer to third parties to the extent permitted by law, share, classify, anonymize, and process your personal and special categories of personal data in the manner specified in the Law, in accordance with all legal regulations and legislation, and only within the stated purpose and scope, while remaining within the limits stipulated by legal regulations as explained in the Law and detailed below.
This privacy notice has been prepared by INTERNATIONAL POLYCLINIC AND HEALTH SERVICES TRADE CORPORATION (Private Özel SRK ) to fulfill its “duty to inform” data subjects under the relevant law, and its purpose is to provide information regarding the protection of personal data.
Data Controller
In accordance with the Personal Data Protection Law No. 6698, your personal data may be processed by INTERNATIONAL POLYCLINIC AND HEALTH SERVICES TRADE JOINT STOCK COMPANY as the data controller.
Processed, Collected, and Used Data
Personal data, including but not limited to your personal and special categories of personal health data obtained for the purpose of providing our services, such as your name, surname, Turkish ID number (or passport number or temporary Turkish ID number if you are not a Turkish citizen), place and date of birth, marital status, gender information, various identification documents that can identify you, contact information such as your address, phone number, and email address, your medical history in your polyclinic file, reports, information indicating your disease history, examination and diagnosis data, data related to procedures applied to you, doctor's analyses and comments, prescription information, appointment information, photographs, all types of images, audio/camera recordings and images obtained from continuous camera recordings in our polyclinic, laboratory and imaging results, test results, and health and sexual life data obtained during the provision of all kinds of medical examination, diagnosis, treatment, and care services, as well as your private health insurance data and Social Security Institution data, etc., are considered personal data. Your personal data is collected directly from you in physical or electronic environments during the receipt of healthcare services, through your shares in phone or email correspondence, your visit to our website, or while you are at our polyclinic.
Your personal data may be processed in a manner related and proportionate to the purposes specified in Article 3 below, and may be transferred to the individuals, institutions, and organizations mentioned in Article 4, either with your consent or for reasons stipulated by law.
Purpose of Processing Personal Data
At INTERNATIONAL POLYCLINIC AND HEALTH SERVICES TRADE JOINT STOCK COMPANY, your personal data may be processed for the following purposes.
– To fulfill our legal obligations and the requirements of the requested services as stipulated in the Health Services Basic Law No. 3359, the Decree Law No. 663 on the Organization and Duties of the Ministry of Health and its Affiliated Institutions, the Regulation on Private Health Institutions Providing Outpatient Diagnosis and Treatment, the Personal Data Protection Law No. 6698, the Regulation on the Processing of Personal Health Data and Ensuring its Privacy, and other relevant legislation,
– Identity verification and authentication to prevent your personal data from being accessed by others,
– Protecting public health, providing preventive medicine, medical diagnosis, treatment, and care services, and planning and managing healthcare services and their financing,
– Planning and managing the internal operations of our polyclinic and daily medical activities,
– Providing you with personalized medication, medical supplies, and devices, and applying specific treatment methods,
– Notifying you about your appointment, providing information, and/or sending appointment reminders if you make an appointment,
– Fulfilling emergency and intervention requirements,
– Fulfilling legal and regulatory obligations,
– Sharing information and responding to requests from the Ministry of Health, judicial authorities, and other public institutions and organizations in accordance with legal provisions,
– Verifying your eligibility with institutions/organizations contracted with our polyclinic or ensuring financial agreement with these institutions regarding the healthcare services provided to you,
– Sharing requested information and verifying identity with contracted institutions/organizations, especially private insurance companies, within the scope of healthcare service financing,
– Processing your payments, e-invoicing, e-archive invoicing, and, if necessary, handling refunds, changes, and corrections, as well as issuing invoices for the services we provide,
– Taking all necessary technical and administrative measures for data security within our polyclinic's systems and applications,
– Analyzing your healthcare service usage to implement, develop, and improve the services provided to you, storing your health data, and, without limitation, responding to your questions and complaints regarding medical diagnosis, analyses, examinations, laboratory services, treatment, and other healthcare services,
– Carrying out risk management and quality improvement activities,
– Sharing information with you via your preferred communication channel within the scope of treatment and services, and identifying transaction details,
– Providing necessary information in line with the requests and audits of regulatory and supervisory bodies and official authorities,
– Retaining information related to your health data that must be stored according to relevant legislation,
– Ensuring compliance with the company's internal policies and principles,
– Measuring and increasing patient satisfaction following the healthcare services you receive,
– Enabling the transfer and follow-up of your complaints and requests to our company,
– If you have given communication consent, carrying out special promotional and informational activities for you and ensuring your benefit, conducting marketing and campaign activities, sending newsletters/brochures, performing data analysis research, and contacting you for informational purposes regarding our services,
– Backing up/archiving, storing, and retaining transaction records, complying with information retention, reporting, and notification obligations under relevant legislation, and fulfilling our legal obligations,
Your personal data, which is collected and processed in accordance with applicable laws and regulations, may be transferred to the physical archives and/or information systems of Özel SRK Hizmetleri ve Tic. Ltd. Şti. and retained both digitally and physically for the period specified in Article 5.
To Whom and For What Purpose Personal Data May Be Transferred
By ensuring all necessary technical and administrative measures are taken to provide an appropriate level of security in accordance with the Personal Data Protection Law and relevant legislation, your personal and special category data may be transferred for the purposes stated in the third section to: individuals, institutions, and/or organizations permitted by the provisions of the Basic Law on Health Services No. 3359, the Decree-Law No. 663 on the Organization and Duties of the Ministry of Health and its Affiliated Institutions, the Regulation on Private Health Institutions Providing Outpatient Diagnosis and Treatment, the Personal Data Protection Law No. 6698, the Regulation on the Processing of Personal Health Data and Ensuring its Privacy, and other relevant legislation; relevant banks and online payment systems depending on your preferred payment method; to the relevant insurance company, foundation, fund, and intermediary institutions if you have received services within the scope of insurance, foundations, or funds; infrastructure providers to resolve your complaints and offer you better service; to relevant institutions, organizations, and infrastructure providers within the scope of e-invoicing and e-archive invoicing processes; our partnered server hosting, archiving, storage, and software service providers for backing up, storing, archiving, and retaining transaction records; our company's employees, company partners, and business partners, legal, financial, and tax advisors, auditors, and all private law real and legal persons, as well as all public institutions and organizations permitted by legal provisions, for the resolution of your complaints or any issues that arise, or for the fulfillment of our legal obligations. When your personal data is transferred to the third parties mentioned in this article, the transfer will only be made to the extent necessary and relevant.
We would like to emphasize that your personal data may need to be disclosed to authorized authorities, strictly limited to the purpose and in a proportionate manner, in situations where the privacy of personal medical records must be restricted to protect public health (for example, as per the obligation to report infectious diseases regulated in Article 58 of Public Health Law No. 1593) or in cases of legal necessity such as the duty to report a crime. Additionally, your data may be shared with another physician for consultation regarding your health condition.
Methods of Collecting Personal Data and Retention Period
Your personal data may be Özel SRK verbally, written, visual, or electronic formats; via telephone, SMS, and similar telecommunication means; online through the Social Security Institution system; from records shared when utilizing private insurance; and/or from records of other healthcare institutions and organizations if you provide them yourself; as well as from emails you send, call center call records, the website, mobile applications, test results obtained at our clinic, examinations, films, X-rays, graphs, MRI results, prescriptions, camera recordings, photographs, and similar records and documents; through audio and video recordings made for security purposes via verbal, written, printed, and similar channels such as magazines and subscription forms; and through both automated and non-automated means, in written, verbal, or electronic formats, are collected and stored in both physical and digital environments.
Your personal data will be stored in compliance with the periods stipulated by Law No. 6698 on the Protection of Personal Data (KVKK), relevant legislation, and other applicable legal provisions. If no such period is stipulated, your data will be stored only for as long as necessary for the healthcare service provided to you and for the purpose for which it was processed. According to Article 7/1 of the KVKK, your personal data will be deleted, destroyed, or anonymized when the purpose requiring its processing ceases to exist and/or when the mandatory retention periods for processing your data under legislation expire.
Rights of the Personal Data Owner and Exceptions
In accordance with the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data (Council of Europe Convention No. 108), Article 8 of the European Convention on Human Rights, Article 20 of the Constitution, and Law No. 6698 on the Protection of Personal Data (KVKK);
By applying to our Company in writing or through other methods to be determined by the Personal Data Protection Board, regarding your personal data, you have the right to:
– Learn whether your personal data is being processed,
– Request information about the scope of processing if your personal data has been processed, and if so, access and obtain copies of this data,
– Learn the purpose for which your personal data is processed and whether it is used in accordance with that purpose,
– Know the third parties to whom your personal data has been transferred, whether domestically or abroad,
– Request the correction of your personal data if it is incomplete or incorrectly processed,
– Request that changes made to your personal data be notified to the individuals or institutions to whom the data was shared,
– Request the deletion or destruction of your personal data within the framework of the conditions stipulated in Article 7 of the KVKK,
– Request that the aforementioned actions be notified to third parties to whom your personal data has been transferred,
– Object to any outcome against you resulting from the exclusive analysis of your personal data by automated systems, and
– Demand compensation for damages incurred due to the unlawful processing of your personal data.
You may submit your requests regarding personal data, along with the necessary identifying information and explanations about the right you wish to exercise, by sending a petition written in Turkish via registered mail, notary public, or hand delivery to our Company's address at “Teşvikiye Mah. Hakkı Yeten Cad. Doğu İş Merkezi No:15/8 Şişli/İSTANBUL”. Our Company will finalize your requests within the application free of charge within 30 days at the latest. However, if the process requires an additional cost, a fee determined by the Board may be charged. Our Company reserves the right to accept or reject the request by explaining its reasons and to notify the relevant person of its response in writing or electronically. If the request in the application is accepted, our Company will fulfill your request. If a fee was charged due to an error by our Company, the fee will be refunded to the relevant person. In cases where the application is rejected, the response provided is deemed insufficient, or no response is given within the specified period, the data subject reserves the right to file a complaint with the Board within 30 days from the date they learn of our Company's response, and in any case, within 60 days from the date of application. According to Article 14/2 of the KVKK, a complaint cannot be filed with the Board without first exhausting the application process to our Company, which is the data controller. The right of individuals whose personal rights have been violated to claim compensation under general provisions is reserved.
According to Article 28/2 of the KVKK, Article 11, which regulates your rights (excluding the right to demand compensation for damages), shall not apply in the following cases:
a) When personal data processing is necessary for the prevention of crime or for criminal investigation,
b) When personal data that has been made public by the data subject themselves is processed,
c) When personal data processing is necessary for the performance of auditing or regulatory duties by authorized public institutions and organizations, and professional organizations with public institution status, based on the authority granted by law, or for disciplinary investigations or prosecutions,
d) When personal data processing is necessary for the protection of the state's economic and financial interests regarding budget, tax, and financial matters.
Cases Where Personal Data May Be Processed Without Explicit Consent Under KVKK
According to Article 5 of the KVKK, your personal data may be processed without your explicit consent in the following cases:
– In cases explicitly provided for by law,
– If you are unable to express your consent as a data subject due to actual impossibility, or if your consent is not legally valid, and the processing of your personal data is necessary to protect your life or physical integrity or that of another person,
– If the processing of your personal data belonging to the parties of a contract is necessary, provided that it is directly related to the establishment or performance of that contract,
– If it is necessary to fulfill a legal obligation,
– If your personal data has been made public by you,
– If data processing is necessary for the establishment, exercise, or protection of a right,
– If data processing is necessary for INTERNATIONAL POLIKLINIK VE SAĞLIK HİZMETLERİ TİCARET ANONİM ŞİRKETİ, provided that it does not harm your fundamental rights and freedoms,
– Furthermore, your personal health data may be processed by individuals under a confidentiality obligation or by authorized institutions/organizations without seeking your explicit consent, for the purposes of protecting public health, preventive medicine, medical diagnosis, treatment and care services, and the planning and management of health services and their financing.
Explicit consent is not required for disclosures, uses, and transfers to individuals/institutions who may request information due to legal obligations arising from the legislation our Company is subject to and/or due to legal necessities.
Business Name: Özel SRK Services and Trade Ltd. Co.
Contact Address: ÜNALAN MH.ÜNALAN CD.BOĞAZİÇİ ST.N.2/1A/1 ÜSKÜDAR
Mersis No: 0478-0824-3990-0001
Status Registration No: 125548-5 Chamber Registration No: 1115409
Contact Phone: (0216) 363 97 93
Fax Number: (0216) 363 97 93
Email Address: info@ozelsrkpolikinlik.com
I have read and understood the Privacy Notice prepared by INTERNATIONAL POLYCLINIC AND HEALTH SERVICES CORPORATION ( Özel SRK ), and I have also been provided with verbal information regarding this matter,
I have been informed about the purposes of processing my personal data, methods of collection and legal grounds, my rights regarding the protection of my personal data, cases where my data may be transferred, mandatory circumstances, data security, and my rights of application, all detailed in the Clarification text on the Processing/Protection of Personal Data,
I consent to the collection, storage, and sharing of all my personal data, including my health data, in accordance with the principles outlined above, by INTERNATIONAL POLYCLINIC AND HEALTH SERVICES TRADE CORPORATION (Private Özel SRK ) and its employees, and that such data may be shared in the specified circumstances, as well as being communicated to me via the mobile devices, the internet, or by mail to my address, etc., as I have explicitly consented to.
*As per the Patient Rights Regulation; one copy of the form will be given to you. If you do not receive the form, please inform the person who obtained the consent.
Patient Name Surname……………………………
Address:
Email:
Phone:
Signature:…………Date: ……./……./…………Time:…..
If the patient is under 18 years of age or unconscious:
Patient's Next of Kin Name Surname:…………………………….
Signature:…………Date: ……./……./…………Time:…..
Relationship: …………………………….
Write “I have read and understood” in your own handwriting:……………………………………………………………………..
INTERPRETER (If the patient has a language/communication problem)
The information I translated during the consultation has been understood by the patient/patient's next of kin.
Interpreter's Name Surname:…………………………….
Signature: …………Date: …../……./……… Time:……