Data Processing Policy
Without an obligation to provide in-area care, the Uniklinik Fogászati Központ Kft. offers dental outpatient services without social security protection and other beauty care (dental) services, that is health care services (hereinafter referred to as the “Service”) at the dental office at 2 Örs vezér square 1148 Budapest.
Uniklinik Fogászati Központ Kft. considers the protection of personal and sensitive data of great importance during this activity.
In each case, we will process the personal and sensitive data made available on the anamnesis in accordance with applicable laws, we will ensure their safety, take every technical and organizational measure, and establish procedural rules that are required to comply with, especially but not exclusively, Act CXII of 2011 on Informa¬tional Self-determination and Freedom of Information (Info tv.) and REGULATION 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (EU) 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, and repealing Directive 95/46/EC (Gen¬eral Data Protection Regulation).
If a person under the age of 18 wants to use the Service, the consent of the legal representative (for example a parent, guardian) is also required. We cannot perform any dental treatment without the consent of the legal representative.
It is of utmost importance for Uniklinik Fogászati Központ Kft. to receive feedback from the patients about the service having been provided and about its quality, which helps us to continuously modify and develop certain Services and the con¬dition of their performance. You may provide your feedback by completing the Pa¬tient Satisfaction Questionnaire (hereinafter referred to as the “Patient Satisfaction Questionnaire”) sent to us after the provision of the Service.
This brochure sets out the principles governing the processing of personal and sen¬sitive data arising from the use of the Service.
I. Name of the data controller
The Service is provided by Uniklinik Fogászati Központ Kft. (seat: 2 Örs vezér square 1148 Budapest; company registration number: 01-09-710831; tax number: 12935394-1-42; phone number: +36 1 222 9150; e-mail address: [email protected], represented by Dr Péter Jancsecz, Managing Director entitled to sign in the name of the company), which manages your personal data during the Service in accordance with the provisions of this brochure, independently determines the purpose and means of data management, and makes the decisions related to data management.
Based on the above, your personal data will be managed by the following companies as set out in this brochure:
II. Scope of data managed, purpose of data processing
You have contacted us to be provide the Service, that is, to provide you the neces¬sary or the requested dental care. Uniklinik Fogászati Központ Kft. manages the personal data that you have provided on the first page of this anamnesis in order to provide the Service.
In addition to the above, as we provide health services, it is necessary that those sensitive data are processed, which you provide to us on the second page of the anamnesis.
We would like to inform you that before starting dental services, not including dental hygiene services performed by the dental hygienists, a panoramic X-ray will be taken, in accordance with the general terms and conditions. If you have had an X-ray taken within 6 months and you make it electronically available for us prior to the commencement of the Service, we will treat the sensitive data contained therein as part of medical documentation in accordance with this brochure.
In each case, please provide real and genuine personal and sensitive data. You are responsible for the authenticity and accuracy of the personal and sensitive data you have provided. To the maximum extent permitted by law, we exclude our liability for damages resulting from inaccurate, incomplete, or not real provision of data.
Please note that the provision of data specified above is required for the performance of the Service. If you do not provide the required data, we will not be able to provide dental care.
It should be added that the Patient Satisfaction Questionnaire will be sent to the email address you have provided after the provision of the Service.
III. Legal basis for data management
Your personal data will be processed for the purpose of concluding the contract for the provision of the Service, and your sensitive (health) data will be processed for medical treatment, namely dental treatment.
Based on the foregoing, personal data will be processed pursuant to point b) of subsection (1) of Article 6 of the GDPR (it is required for the performance of a contract to which you are one of the parties), sensitive data is managed on the basis of an authorisation by law, pursuant to point h) of subsection (1) of section 4 of Act XLVII of 1997 on Management and Protection of Health Data and Personal Data relating thereto (Eüak) (pursuant to point (h) of subsection (2) of Article 9 of the GDPR for the provision of health care services).
The purpose of data management regarding the Patient Satisfaction Questionnaire is to improve the quality of our Service and its conditions and therefore the legal basis for data management is the Service Provider’s legitimate interest (point f) of subsection (1) of Article 6 GDPR).
IV. Means, location and duration of data management
The personal and sensitive data provided will be stored on a paper format in a locked room and safe at 2 Örs vezér square 1148 Budapest.
We would like to inform you that you are not entitled to withdraw your consent in view of the data management based on the contract. After the provision of the Service, you also have no right to the cancellation of your personal and sensitive data, as we are obliged to preserve medical records for 30 years pursuant to subsection (1) of Section 30 of the Eüak., and imaging diagnostic images (such as any X-rays of your dentures) under subsection (2) of Section 30 pursuant to the same Act for 10 years.
If you request the cancellation of your personal data after your appointment reservation but prior to the provision of the Service, we will only be able to comply with this request if you are not required to pay the amount of 15,000 HUF availability fee under the General Terms and Conditions. If you are required to pay an availability fee, you must keep the invoice issued for this purpose as an accounting document for 8 (eight) years to meet the requirements of the retention period as specified in subsection (1) of Section 169 of Act C of 2000 on Accounting.
For the purposes of data management related to the Patient Satisfaction Questionnaire, the data will be stored on a password protected server at 2 Örs vezér square 1148 Budapest until the termination of the legitimate interest.
V. Data processing, data transfer
We would like to inform you that Uniklinik Fogászati Központ Kft. provides the Service through its employees and its contracted dentists.
The list of contracted dentists (data processors, as described in this brochure) can be found at the link below or is handed over in person at the dental office.
Please also be aware of the fact that in case of the receival, removal and replacement of implants, pursuant to the provisions of subsection (3) of Section 101/C of Act CLIV of 1997 on Health, we must forward your name (first and last name, name at birth, date of birth, mother’s name at birth, place of residence, other contact details) to the National Health Insurance Fund, so if any data is not available, we will contact you, so that you can provide us with that particular data as it’s our legal obligation to forward it.
In addition to the above, if we are required by law (such as Section 23 of the Eüak.) to disclose your data, we will have to comply with such a request, but otherwise we will not transfer or disclose your personal and sensitive data to a third party not listed above.
VI. Your rights, possibilities to remedies
You have a number of rights related to the processing of your personal and sensitive data, which you may exercise by sending a request to one of the contact details of Uniklinik Fogászati Központ Kft. as defined in Section I.
The right to access to and rectify personal data
You have the right to access to your personal and sensitive data at any time, to request a copy of them, and to correct or update them.
Pursuant to the right of access, you have the right to receive information about the following:
(a) the purposes of the processing;
(b) the categories of personal data concerned;
(c) the recipients or categories of recipients to whom or to which the personal data have been or will be communicated, including particular third-country recipients or international organizations;
(d) where applicable, the planned period of time while the personal data will be stored;
(e) the right of the data subject to request the data controller to rectify, cancel or limit the processing of personal data concerning him or her and to object to the processing of such personal data;
(f) the right to lodge a complaint with a supervisory authority.
We understand the importance of this, so if you would like to exercise these rights, please contact us through one of the contact details provided in section I.
Right to portability
Your personal and sensitive data are portable, so you have the right to receive them in a structured, widely used, machine-readable format. This means that you will receive your personal data in a computer-readable format which is possible to be electronically transmitted to another person.
If you wish to exercise your right to data portability, please contact us through one of the contact details specified in Section I.
Right to cancel personal data
You have the right to request that your data be cancelled if
(a) your personal data are no longer necessary for the purpose(s) for which they were collected; or
b) there is no legal basis for data management and we are not obliged by legislation (law) to manage it; or
(c) you object to the processing of your personal data;
(d) the processing of personal data is not performed lawfully;
(e) the cancellation of your personal data is justified with the purpose of regulatory compliance.
Please note that the personal and sensitive data you provide on the anamnesis, as well as the notes made by your doctor (s), shall be preserved for 30 years pursuant to subsection (1) of Section 30 of Eüak, we cannot cancel them even at your request.
Any possible records (such as X-rays, CT scans) taken with the imaging diagnostic procedure shall be preserved for 10 years, pursuant to subsection (2) of Section 30 of Eüak, so we cannot cancel them even at your request within 10 years from the recording.
Any possible invoice about availability fees must be retained for 8 years pursuant to subsection (1) of Section 169 of Act C of 2000 on Accounting.
After the mandatory retention period, your data will immediately and permanently be cancelled. If you wish to cancel your personal data, please contact us through one of the contact details provided in Section I.
The right to restrict data management
You may limit the processing of your personal and sensitive data if
(a) you believe that the stored personal and sensitive data related to you are inaccurate; or
(b) the processing of personal and sensitive data is not performed lawfully, but instead of their cancellation, you would prefer to restrict their processing; or
(c) we no longer need your personal data for the purpose(s) for which they were originally collected, but you have a claim for these data for the purpose of filing, asserting or defending against a legal claim, or
d) you have objected to the handling of your personal data and you are waiting for the confirmation that your interests related to the objection supersede the legal basis for the processing of your data.
If you would like to restrict the processing of your personal data, please contact us through one of the contact details provided in Section I.
Right to object
You may object at any time to the processing of your personal and sensitive data. If you have such intentions, please contact us through any of the contact details provided in Section I.
Right to apply to the supervisory authority
You have the right to lodge a complaint at any time with the National Authority for Data Protection and Freedom of Information (address: 22/c, Szilágyi Erzsébet fasor, 1125 Budapest, Mailbox number: 5; Phone number: +36 (1) 391-1400, e-mail address: [email protected]) as a supervisory authority.