Personal Data Protection and Processing Policy

 

You can access the "Personal Data Protection Law (KVKK)" Application form at kvkk.gov.tr.

 

Protection of personal data is among the most important priorities of ''SELİM BİLGİN PRIVATE ORAL AND DENTAL HEALTH POLYLINK HİZMETLERİ SANAYİ TİCARET LİMİTED ŞİRKETİ''. Necessary sensitivity is given to the security of personal data, and great importance is attached to patient privacy and the preservation of all personal data belonging to our patients by processing them in the best possible way and with care. In addition to our patients, our companions, visitors, all our employees and employees of the institutions and organizations we cooperate with; According to the Law on the Protection of Personal Data No. 6698, the regulation on the Processing and Privacy of Personal Health Data and the relevant legislation, it has been adopted as a corporate policy to protect personal data within the framework of the following basic principles.

 

• Processing personal data in accordance with the law and honesty rules,

• Keeping personal data accurate and up-to-date when necessary,

• Processing personal data for specific, explicit and legitimate purposes,

• Related, limited and measured processing of personal data for the purpose for which they are processed,

• Keeping personal data for as long as required by the relevant legislation or for the purpose for which they are processed,

• Clarifying and informing personal data owners,

• Establishing the necessary system for personal data owners to exercise their rights,

• To take the necessary measures in the protection of personal data,

• To act in accordance with the relevant legislation and KVK Board regulations in the transfer of personal data to third parties in line with the requirements of the processing purpose,

• Showing the necessary sensitivity to the processing and protection of sensitive personal data,

• Deletion and destruction of personal data in a legally defined manner and time

 

Aim

 

The main purpose of this Policy is to make explanations about the personal data processing activity carried out in accordance with the law and the protection of personal data by "SELİM BİLGİN PRIVATE ORAL AND DENT HEALTH POLINK HİZMETLERİ SANAYİ TİCARET LİMİTED ŞİRKETİ", in this context, our patients, visitors, employees and institutions. is to ensure transparency by informing the persons whose personal data are processed by our Clinic, especially our officials, employees, shareholders and officials of the institutions we cooperate with, and third parties. Personal data processed by ''SELİM BİLGİN PRIVATE ORAL AND DENTAL HEALTH POLYLINK HİZMETLERİ SANAYİ TİCARET LİMİTED ŞİRKETİ'' are collected by automatic or non-automatic methods, although it may vary depending on the health services provided. Our patient representatives our physicians, health professionals, etc. our employees, subcontractors and their employees and companies involved in all kinds of commercial activities; Special quality personal data and general personal data, especially health data collected verbally, in writing or electronically through our call center, website, online services and similar means, can be processed for the purposes listed below.

 

Execution of medical diagnosis, treatment and care services, Protection of public health, planning and management of preventive medicine health services and financing; to inform our patients about the appointment; planning and managing the internal procedures of our clinic, analyzing for the purpose of improving health services; training and development of our employees, protecting the personal processes and legal rights of our employees, monitoring and preventing abuse and unauthorized transactions; performing risk management and quality improvement activities; conducting research; fulfilling legal and regulatory requirements; billing for our services; confirming your identity; Confirming your relationship with the institutions contracted with our clinic; sharing all kinds of information requested by private insurance companies within the scope of financing health services; to be able to answer all your questions and complaints about our health services; Taking all necessary technical and administrative measures within the scope of data security of our clinic's systems and applications; analyze your use of healthcare services and store your health data in order to develop and improve the healthcare services we provide to you; keeping information about your health data, which must be kept in accordance with the relevant legislation; Providing financial reconciliation regarding the health services offered to you with the institutions we have contracted with, banks and all institutions (public and private) from which health expenditures are collected; sharing the requested information with the Ministry of Health and other public institutions and organizations in accordance with the relevant legislation;

 

Personal data, in all kinds of verbal, written or electronic media, for the purposes mentioned above and health services to be provided within the determined legal framework, and in this context, "SELİM BİLGİN ÖZEL OĞLU DENTAL HEALTHCARE POLİKLINK HİZMETLERİ SANAYİ TİCARET LİMİTED ŞİRKETİ" fulfills its contracts and legal obligations as required. It is collected and processed for the purpose of its complete fulfillment.

 

Scope

 

This Policy; It covers the personal data defined below, which is processed automatically or not, of our patients, companions, visitors, institution officials, employees, employees, shareholders and officials of persons, organizations and institutions with whom we have cooperation and all kinds of legal relations, and third parties.

 

Name, surname, TR Identity number, passport number or temporary TR Identity number, place and date of birth, gender, marital status, clinic-specific protocol number and other identification data identifying the patients; financial data such as address, telephone number, e-mail address, etc. contact data, payment and billing information; audio and digital information that can be obtained by electronic or non-electronic means; General and special personal data, especially personal health data obtained during the execution of all medical diagnosis, examination, treatment and care services; Data on private health insurance and Social Security Institution data for the financing and planning of health services, health and identity data sent via websites, all visual (digital and non-digital) records 

 

The scope of application of this policy according to personal data owners groups may be the entire policy (such as our patients); may also have only some provisions (for example, only our employees, suppliers, etc.)

 

Personal data may also be processed when a call center or website is used to use online services, on the intranet, when participating in training, events organized by the hospital, or when visiting web pages.

 

Definitions

 

Explicit Consent: Consent about a specific subject, based on information and expressed with free will

Anonymization:   It is the change of personal data in such a way that it loses its quality as personal data and this situation cannot be undone. For example masking, aggregation, data corruption etc. making personal data incapable of being associated with a natural person with techniques

Employees, Shareholders and Authorities of Institutions We Collaborate with: Real persons, including shareholders and officials of these institutions, working in institutions (such as but not limited to business partners, suppliers) with which our clinic has any business relationship.

Processing of Personal Data: Obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available personal data by fully or partially automatic or non-automatic means provided that it is a part of any data recording system, All kinds of operations performed on data such as classification or prevention of use

Personal Data Owner: The natural person whose personal data is processed. For example, patients and employees

Personal Data: Any information relating to an identified or identifiable natural person. Therefore, the processing of information regarding legal persons is not within the scope of the Law. For example, name, surname, TRN, e-mail, address, date of birth, credit card number, bank account number, etc.

Patient: Person who applied to our clinic for examination and treatment and received outpatient or inpatient treatment.

Special Quality Personal Data: Data related to race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, dress, association, foundation or union membership, health, sexual life, criminal conviction and security measures, and biometric and genetic data special quality data

Institution Official: General Manager of the Institution and other authorized natural persons

Third Party: Third -party real persons (For example, employees or officials of the company from whom the service is received, Companion etc.)

Data Processor: It is the natural and legal person who processes personal data on behalf of the data controller based on the authority given by him. For example, the IT company that keeps the data of our clinic, all the employees who enter the patient data into the system.

Data Controller: The person who determines the purposes and means of processing personal data and manages the place where the data is kept systematically (data recording system).

Visitor: Real persons who have entered the physical areas of our clinic for various purposes or visited our websites.

 

Implementation of the Policy and Related Legislation

 

The processing and protection of personal data is carried out within the framework of the relevant legal regulations in force. ''SELİM BİLGİN PRIVATE ORAL AND DENTAL HEALTH POLYCLINIC SERVICES SANAYİ TİCARET LİMİTED ŞİRKETİ'' Personal Data Protection Policy has been prepared in accordance with current regulations.

 

The policy has been formed by integrating with the practices of "SELİM BİLGİN PRIVATE ORAL AND DENTAL HEALTH POLYLINK HİZMETLERİ SANAYİ TİCARET LİMİTED ŞİRKETİ" within the framework of the rules set forth by the relevant legislation. It carries out the necessary preparations by adhering to the effective periods stipulated in the KVK Law. When necessary, the above-mentioned personal data can be provided in the Health Services Basic Law No. 3359, Decree Law No. 663 on the Organization and Duties of the Ministry of Health and its Affiliates, Regulation on Private Hospitals, Regulation on the Processing of Personal Health Data and Protection of Privacy and regulations of the Ministry of Health, etc. It will be transferred to the physical archives and information systems of our clinic and/or our suppliers, which can be processed within the framework of the provisions of the legislation.

 

Ensuring the Security of Personal Data

 

Our clinic takes the necessary technical and administrative measures to ensure the optimum level of security in order to prevent the unlawful processing of the personal data it processes and to ensure the preservation of the data, and in this context, it makes or has the necessary inspections made.

 

The actions and measures taken by our clinic to ensure "data security" in accordance with Article 12 of the KVK Law are listed below.

 

• Our clinic takes technical and administrative measures according to technological possibilities and application costs in order to ensure that personal data is processed in accordance with the law. Employees are informed that they cannot disclose the personal data they have learned to others in violation of the provisions of the KVKK and cannot be used for purposes other than processing, and that this obligation will continue after they leave their job, and necessary commitments are taken from them in this direction.

• Our clinic takes technical and administrative measures to prevent reckless or unauthorized disclosure, access, transfer or any other unlawful access to personal data.

• Our clinic raises awareness as data processing institutions, such as business partners and suppliers, to whom personal data has been transferred, on preventing the illegal processing of personal data, preventing illegal access to data, and ensuring that data is kept in accordance with the law.

• Obligations that our clinic has to comply with when processing personal data as a data controller and the obligation to comply with the legal, administrative and technical measures it has developed in this regard Contracts are made with the data processing institutions with which our clinic is in contact with various titles such as supplier, business partner, in accordance with the nature of the activity they carry out in the field of data processing.

• Our clinic performs or has had the necessary inspections done within its own body. The results of these audits are reported to the relevant department within the scope of the internal functioning of the Institution and necessary activities are carried out to improve the measures taken.

• Our clinic operates the system that ensures that the personal data processed in accordance with Article 12 of the KVK Law is obtained by others illegally, and this situation is reported to the relevant personal data owner and the KVK Board as soon as possible.

 

Data Owner's Rights; Claiming Rights, Communication Channels and Evaluation of Data Owners' Requests

 

Our clinic carries out the necessary channels, internal functioning, administrative and technical regulations in accordance with the 13th article of the KVK Law in order to evaluate the rights of the personal data owners and to provide the necessary information to the personal data owners.

In case personal data owners submit their requests regarding their rights listed below to our Clinic in person with a personal application and with a special authorized power of attorney, our Clinic concludes the request as soon as possible and within thirty days at the latest, free of charge, depending on the nature of the request. Personal data owners;

• Learning whether personal data is processed or not,

• If personal data has been processed, requesting information about it,

• To learn the purpose of processing personal data and whether they are used in accordance with the purpose,

• Knowing the third parties to whom personal data is transferred in the country,

• Requesting correction of personal data in case of incomplete or incorrect processing,

• Requesting the deletion or destruction of personal data,

• In case of correction, deletion or destruction of personal data, requesting these transactions to be notified to third parties to whom personal data has been transferred,

• Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,

• It has the right to demand the compensation of the damage in case of loss due to unlawful processing of personal data.

 

Pursuant to paragraph 1 of Article 13 of the KVK Law, the request regarding the exercise of the above-mentioned rights must be submitted to our Clinic (data controller) in “written” form.

 

For the exercise of the rights specified within the framework of the KVK, the request is sent to our Clinic, together with the necessary information identifying the identity and the explanations regarding the rights desired to be exercised, also specifying which right is related to the exercise specified in Article 11 of the Law; It will ensure that the application regarding the request is answered more quickly and effectively.

 

Protection of Private Personal Data

 

''SELİM BİLGİN PRIVATE ORAL AND DENTAL HEALTH POLYCLINIC SERVICES INDUSTRY AND TRADE LIMITED COMPANY'' carefully protects personal data with its technical and administrative facilities. The security measures taken by our clinic are provided at an optimum level, taking into account the technological possibilities and possible risks.

 

A group of personal data is defined as "special quality personal data" in the KVK Law due to the risk of causing discrimination or victimization of individuals when processed unlawfully.

 

These data are; Data related to race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, clothing, association, foundation or union membership, health, sexual life, criminal conviction and security measures, and biometric and genetic data.

 

The protection of the above-defined data, which is determined as "special quality" by the KVK Law and processed in accordance with the law, is treated with sensitivity.

 

Clarifying and Informing the Personal Data Owner

 

In accordance with Article 10 of the KVK Law, it informs the personal data owners during the acquisition of personal data. In this context, the identity of our Clinic, the purpose for which personal data will be processed, to whom and for what purpose the processed personal data can be transferred, the method of personal data collection and the legal reason, and the rights of the personal data owner within the scope of Article 11 of the KVK Law during the acquisition of personal data by our Clinic. related lighting.

 

Article 20 of the Constitution states that everyone has the right to be informed about their personal data. Accordingly, in Article 11 of the KVK Law, "requesting information" is also listed among the rights of the personal data owner. In this context, our clinic provides the necessary information in case the personal data owner requests information in accordance with the 20th article of the Constitution and the 11th article of the KVK Law.

 

Our clinic announces the corporate policy on the protection of personal data to personal data owners and those concerned, with various publicly available documents, informing the relevant persons in personal data processing activities, and ensures accountability and transparency within this framework. In addition, the relevant persons of our clinic; It also informs people about their activities and the articles in the law in different ways, especially when they apply for their "explicit consent".

 

Processing of Personal Data

 

Our clinic, in accordance with Article 20 of the Constitution and Article 4 of the KVK Law, regarding the processing of personal data; accurate and up-to-date, in accordance with the law and honesty; for specific, clear and legitimate purposes; engages in personal data processing activities in a connected, limited and measured manner for this purpose.

 

Our clinic retains personal data for as long as required by law or for the purpose of processing personal data.

 

Our clinic processes personal data in accordance with Article 20 of the Constitution and Article 5 of the KVK Law, based on one or more of the conditions in Article 5 of the KVK Law regarding the processing of personal data.

 

Our clinic acts in accordance with the regulations stipulated for the processing of special quality personal data in accordance with Article 6 of the KVK Law.

 

Our clinic acts in accordance with the regulations stipulated in the law and set forth by the KVK Board on the transfer of personal data in accordance with the 8th and 9th articles of the KVK Law.

 

Processing of Personal Data in Compliance with the Principles Established in the Legislation

 

Processing in Compliance with Law and Integrity

 

Our clinic; acts in accordance with the principles introduced by legal regulations and the general rule of trust and honesty in the processing of personal data. Our clinic takes into account the proportionality requirements in the processing of personal data, and does not use personal data for any other purpose.

 

 

Ensuring Personal Data Are Accurate and Up-to-Date When Necessary

 

Our clinic; takes the necessary measures to ensure that the personal data it processes is accurate and up-to-date, taking into account the fundamental rights of personal data owners and their own legal interests.

 

Processing for Specific, Explicit, and Legitimate Purposes

 

Our clinic clearly and precisely determines the legitimate and lawful purpose of processing personal data. Our clinic processes personal data in connection with the service it provides and as much as is necessary for them. The purpose for which personal data will be processed by our clinic is notified before the personal data processing activity begins.

 

Being Related to the Purpose for which they are Processed, Limited and Measured

 

Our clinic processes personal data in a way that is suitable for the realization of the determined purposes and avoids the processing of personal data that is not relevant or needed for the realization of the purpose. For example, personal data processing activities are not carried out to meet the needs that may arise later.

 

Retention for as Long as Required for the Purpose of Processing or Envisioned in the Relevant Legislation

 

Our clinic retains personal data only for as long as required by the relevant legislation or for the purpose for which they are processed. In this context, our clinic first determines whether a period is foreseen for the storage of personal data in the relevant legislation, if a period is determined, it acts in accordance with this period, and if a period is not determined, it stores the personal data for the period required for the purpose for which they are processed. Personal data is deleted, destroyed or anonymized by our Clinic in the event that the period expires or the reasons for its processing disappear.

 

Personal Data Processing Conditions

 

Protection of personal data is a constitutional right. Pursuant to the third paragraph of Article 20 of the Constitution, personal data can only be processed in cases stipulated by the law or with the explicit consent of the person. Our clinic is in this direction and in accordance with the Constitution; processes personal data only in cases stipulated by law or with the explicit consent of the person.

 

Although the legal bases for the processing of personal data by our clinic differ, we act in accordance with the general principles specified in Article 4 of the Law No. 6698 in all kinds of personal data processing activities.

 

The express consent of the personal data owner is only one of the legal bases that allow the processing of personal data in accordance with the law. Apart from express consent, personal data may also be processed in the presence of one of the other conditions listed below. The basis of the personal data processing activity can be only one of the conditions stated below, or more than one of these conditions can be the basis of the same personal data processing activity. In case the processed data is special quality personal data; The following conditions apply.

 

• Finding the Explicit Consent of the Personal Data Owner

• Clearly Provided in Laws

• Failure to Obtain Explicit Consent of the Related Person Due to Actual Impossibility

• Being Directly Related to the Establishment or Performance of the Contract

• Fulfilling the Legal Obligation of the Institution

• Publicizing the Personal Data of the Personal Data Owner

• Mandatory Data Processing for the Establishment or Protection of a Right

• Mandatory Data Processing for the Legitimate Interest of Our Clinic

 

Processing of Private Personal Data

 

Our clinic carefully complies with the regulations stipulated in the KVK Law in the processing of personal data determined as "special quality" by the KVK Law.

 

In Article 6 of the KVK Law, a set of personal data that carries the risk of causing victimization or discrimination when processed unlawfully has been determined as "special quality". These data are; Data related to race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, clothing, association, foundation or union membership, health, sexual life, criminal conviction and security measures, and biometric and genetic data.

 

By our Clinic in accordance with the KVK Law; Special categories of personal data are processed in the following cases, provided that adequate measures to be determined by the KVK Board are taken:

 

• If the personal data owner has express consent, or

• If there is no explicit consent of the personal data owner;

• Special categories of personal data other than the health and sexual life of the personal data owner, in cases stipulated by the laws,

• The personal data of the personal data owner regarding his health and sexual life are only for the purposes of protection of public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing, or persons or authorized institutions under the obligation to keep confidential. processed by organizations.

 

Transfer of Personal Data

 

Our clinic can transfer the personal data and sensitive personal data of the personal data owner to third parties (third party companies, institutions, group companies, third real persons) by taking the necessary security measures in line with the personal data processing purposes in accordance with the law. In this direction, our clinic acts in accordance with the regulations stipulated in Article 8 of the KVK Law.

 

Your personal data, within the scope of the Law and other legislation and for the above-mentioned purposes, "SELİM BİLGİN PRIVATE ORAL AND DENTAL HEALTH CARE SANAYİ TİCARET LİMİTED ŞİRKETİ", Medical Centers, Group Companies, Universities, Ministry of Health, sub-units and family medicine centers, private insurance companies (health, retirement and life insurance and similar), Social Security Institution, General Directorate of Security and other law enforcement agencies, General Directorate of Population, Pharmacists Association of Turkey, courts and all public institutions and organizations, without being bound by it, work for medical diagnosis. Laboratories, medical centers and third parties providing health services in the country we are in association with, the health institution to which the patient is referred or the patient himself applies, your authorized representatives,The institution you are affiliated with and/or work with, the third parties we consult, including lawyers, tax consultants and auditors, regulatory and supervisory institutions and official authorities, domestic or foreign systems and/or companies within the group of companies to which our Hospital is affiliated. may be shared with our suppliers, support service providers and business partners whose services we benefit from or cooperate with (for more detailed information, you can apply in writing to our Clinic).It can be shared with domestic or foreign systems and/or companies within the group of companies that our Hospital is affiliated with, our suppliers, support service providers and business partners whose services we benefit from or cooperate with (for more detailed information, you can apply in writing to our Clinic).It can be shared with domestic or foreign systems and/or companies within the group of companies that our Hospital is affiliated with, our suppliers, support service providers and business partners whose services we benefit from or cooperate with (for more detailed information, you can apply in writing to our Clinic). 

 

Transfer of Personal Data Abroad

 

"SELİM BİLGİN PRIVATE ORAL AND DENTAL HEALTH POLYCLINIC SERVICES SANAYİ TİCARET LİMİTED ŞİRKETİ" does not transfer data to ABROAD for personal data processing purposes .

 

Personal Data Received for Physical Space Security

 

Building, Facility Entrances and Personal Data Processing Activities within the Building Facility and Website Visitors

 

Our clinic complies with the regulations in the KVKK in the conduct of camera monitoring for security purposes.

 

In the buildings and facilities of our clinic, personal data processing activities are carried out for monitoring the entrance and exit of patients, staff, visitors and supplier company employees with security cameras.

 

Personal data processing is carried out by our Clinic by using security cameras and recording guest entries and exits. In this context, our clinic acts in accordance with the Constitution, KVK Law and other relevant legislation.

 

Video recordings of our visitors and sound recordings where necessary are taken through the camera monitoring system at the building, facility entrances and inside the facility of our clinic.

 

In our clinic, within the scope of monitoring with security cameras; It aims to increase the quality of the service provided, to ensure its reliability, to ensure the safety of the institution, patients and employees, and to protect the interests of patients regarding the health care and other services they receive.

 

The camera monitoring activity carried out by our clinic is carried out in accordance with the Law on Private Security Services and the relevant legislation.

 

Only authorized institution employees and/or supplier company employees have access to the records recorded and maintained in the digital environment. On the other hand, live camera images can be watched by outsourced security services.

 

Camera recordings are kept for ____.

 

In accordance with Article 12 of the KVK Law, our clinic takes the necessary technical and administrative measures to ensure the security of personal data obtained as a result of camera monitoring.

 

Terms of Deletion, Destruction and Anonymization of Personal Data

 

Although it has been processed in accordance with the provisions of the relevant law as regulated in Article 138 of the Turkish Penal Code and Article 7 of the KVK Law, in the event that the reasons requiring its processing disappear, personal data is deleted, destroyed or anonymized pursuant to the relevant procedures of our Clinic or upon the request of the personal data owner. is brought.

In this context, our Clinic trains, assigns and raises awareness of the relevant business units in order to fulfill its related obligation.

While obtaining the names and surnames of the people who come to our clinic's buildings, or through the texts posted by the Institution or made available to the guests in other ways, the personal data owners are enlightened in this context.

 

To ensure safety by our clinic and for the purposes specified in this Policy; Our Clinic can provide internet access to our Visitors who request it during their stay in our Buildings and Facilities. In this case, log records regarding internet access are recorded in accordance with the Law No. 5651 and the mandatory provisions of the legislation regulated according to this Law; These records are only processed when requested by authorized public institutions and organizations or in order to fulfill our legal obligations in the audit processes to be carried out within the Institution.

 

Only a limited number of Institution employees have access to the log records obtained within this framework. Employees of the Institution who have access to the aforementioned records access and share these records with legally authorized persons only for use in requests or audit processes from authorized public institutions and organizations. A limited number of people who have access to the records declare that they will protect the confidentiality of the data they access with a confidentiality agreement.

 

On the websites owned by our clinic; to ensure that the visitors of these sites perform their visits on the sites in accordance with the purposes of their visit; Internet movements within the site are recorded by technical means in order to show them customized content and to carry out online promotional activities.

 

Detailed explanations regarding the protection and processing of personal data regarding these activities carried out by our clinic are included in the "Website Privacy Policy" texts of the relevant websites.

 

Enforcement of the Policy

 

"SELİM BİLGİN PRIVATE ORAL AND DENTAL HEALTH POLYCLINIC SERVICES INDUSTRY AND TRADE LIMITED COMPANY" Personal Data Protection and Processing Policy enters into force on 01.03.2021. In case of renewal of all or certain articles of the Policy, the effective date of the Policy is the date on which that article is revised for the renewed article.

 

The policy is on the website of our Clinic (https://proestetikdental.com/) is published.