Privacy Notice on the Protection of Personal Data
This privacy notice has been prepared by MEDİGAP Sağlık Hizmetleri San. Tic. A.Ş. (Emek Hospital Gaziantep), in its capacity as data controller, in accordance with Personal Data Protection Law No. 6698 (“KVKK”), the Regulation on Personal Health Data, the Communiqué on the Procedures and Principles to Be Followed in Fulfilling the Obligation to Inform, and the relevant legislation.
Emek Hospital Gaziantep may record, store and update your personal data as described in this Privacy Notice; share it with and transfer it to third parties where permitted and/or required by legislation or agreements (relatives of the service recipient and/or public and/or private legal entities of which the service recipient is an employee or insured person, other public and/or private legal entities, and third parties from which our companies obtain services or with which they cooperate in order to carry out their activities for the purposes specified in the legislation to which they are subject); classify it; and process it in the other ways set out in the KVKK and the relevant legislation.
Your Personal Data Processed with Your Explicit Consent and the Purposes of Processing
The personal data listed below, including special categories of personal data and in particular your health data, may be processed by Emek Hospital Gaziantep in a manner that is connected with, limited to and proportionate to the purposes set out in this section, including but not limited to the following:
Identity Information
Your name and surname,
Your Turkish ID (T.C.) number,
Your passport number or temporary Turkish ID number,
Your place and date of birth,
Your marital status,
Your gender,
Your insurance or patient protocol number.
Contact Information
Your address,
Your telephone number,
Your e-mail address and other contact data,
Your recorded voice calls kept by customer representatives or patient services in line with call centre standards, and the personal data obtained when you contact us by e-mail, letter or other means
Accounting Information
Your bank account number,
Your IBAN,
Your credit card information,
Financial data such as your billing information
Your private health insurance data and Social Security Institution data, for the purposes of financing and planning health services
Records kept for security and monitoring purposes when you visit our hospital
Your camera recording footage,
Your vehicle licence plate information if you use the car park,
Health Information
Your laboratory results,
Your test results,
Your examination data,
Your appointment information,
Your check-up information,
All personal data relating to your health and sexual life obtained during or as a result of the provision of medical diagnosis, treatment and care services, including but not limited to your prescription information,
If you apply for a job at Emek Hospital Gaziantep, your CV and any other personal data provided in this connection; and, if you are an employee or affiliated employee of Emek Hospital Gaziantep, all personal data relating to your employment contract and your suitability for the job.
All personal data obtained by Emek Hospital Gaziantep may be processed for the following purposes: verifying your identity; protecting public health; preventive medicine; carrying out medical diagnosis, treatment and care services; planning and managing health services and their financing; planning and managing the internal workings and day-to-day operations of our hospitals and medical centres; supplying medicines; informing you about your appointment if you book one; carrying out risk management and quality improvement activities; making assessments with a view to developing health services; conducting research; fulfilling legal and regulatory requirements; setting up and maintaining your e-newsletter subscription; verifying your relationship with institutions contracted with our hospitals and medical centres; invoicing for our health services; sharing requested information with private insurance companies within the scope of the financing of health services; sharing requested information with the Ministry of Health and the relevant public institutions and organisations pursuant to the relevant legislation; responding to all your questions and complaints about our health services; taking all necessary technical and administrative measures within the scope of data security for the systems and applications of our hospitals and medical centres; analysing your use of health services and storing your health data in order to develop and improve the health services we provide; providing the necessary information in line with the requests and inspections of regulatory and supervisory bodies and official authorities; training and developing our employees; monitoring and preventing misuse and unauthorised transactions and reversing such transactions; retaining information relating to your health data that must be kept under the relevant legislation; reaching financial reconciliation with our contracted institutions regarding the health services provided to you; measuring patient satisfaction; and, without being limited to these, carrying out and developing medical diagnosis, treatment and care services, planning and managing health services and their financing, increasing patient satisfaction, research and similar purposes.
Cases in Which Explicit Consent Is Not Required for the Processing of Personal Data Under the KVKK
Where at least one of the following conditions exists, your personal data may also be processed without your Explicit Consent.
· It is expressly provided for by law,
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· It is necessary to protect the life or physical integrity of the person concerned who is unable to express consent due to actual impossibility or whose consent is not deemed legally valid,
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· The processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of that contract,
· It is necessary for Emek Hospital Gaziantep to fulfil its legal obligation,
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· The data has been made public by the data subject themselves,
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· Data processing is necessary for the establishment, exercise or protection of a right,
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· Data processing is necessary for the legitimate interests of Emek Hospital Gaziantep, provided that it does not harm the fundamental rights and freedoms of the data subject.
Furthermore, your personal data relating to health and sexual life may be processed by Emek Hospital Gaziantep without seeking your Explicit Consent only for the purposes of protecting public health, preventive medicine, carrying out medical diagnosis, treatment and care services, and planning and managing health services and their financing.
Transfer of Your Personal Data Within Türkiye or Abroad
The personal data of our service recipients may be transferred by Emek Hospital Gaziantep to third parties in Türkiye, and also abroad, within the framework of the personal data transfer conditions and purposes set out in Articles 8 and 9 of the Law, for the purposes of: having our business units carry out the work necessary for the persons concerned to benefit from the services offered by Emek Hospital Gaziantep and conducting the related business processes; planning and executing the commercial or scientific strategies of Emek Hospital Gaziantep; and ensuring the legal, technical and commercial security of persons in a relationship with Emek Hospital Gaziantep. These recipients are private insurance companies; the Ministry of Health and its affiliated sub-units; the Social Security Institution; the General Directorate of Security and other law enforcement forces; the General Directorate of Population; the Turkish Pharmacists' Association; courts and all judicial authorities; central and other third parties; representatives you have authorised; third parties from which we obtain consultancy, including lawyers, tax and financial advisers and auditors; regulatory and supervisory bodies; official authorities; and our business partners and other third parties with which we cooperate in order to develop or provide health services for the purposes stated above.
Method of and Legal Grounds for Collecting and Processing Your Personal Data
Your personal data is obtained through all kinds of oral, written, visual or electronic media, for the purposes stated above, so that health services can be provided within the established legal framework and, in this context, so that Emek Hospital Gaziantep can fully and properly perform its contractual and legal obligations.
Retention of Your Personal Data
As a requirement of the principle of purpose limitation, your personal data is processed to fulfil the purposes explained in this Privacy Notice and, in any event, only for the period required by the practices of Emek Hospital Gaziantep and the customs of commercial life; once these periods expire, it is deleted, destroyed or anonymised.
In addition, your data that, in cases expressly provided for by law, must be processed so that Emek Hospital Gaziantep, as data controller, can fulfil its legal obligation, that has been made public by the data subject themselves, or that must be processed for the legitimate interests of our company as data controller, provided that this does not harm the fundamental rights and freedoms of the data subject, may be used after the periods specified under this heading have passed only to achieve the purposes exhaustively listed in this sentence. Your personal data retained for these reasons will not be accessed for any other purpose and may be used only within the scope of such compelling circumstances.
Once the said compelling circumstances come to an end, your personal data will be deleted, destroyed or anonymised in accordance with the proper procedure.
Rights of the Personal Data Owner as the Data Subject
As the owners of the personal data collected, processed and transferred by Emek Hospital Gaziantep, if you, our valued service recipients, wish to exercise your rights mentioned under this heading and/or under the KVKK in accordance with the procedures and principles set out in this Privacy Notice and the legislation, or if you submit an application to Emek Hospital Gaziantep, the requests in your application will be concluded free of charge within thirty (30) working days at the latest, depending on the nature of the request. However, if the process entails an additional cost for Emek Hospital Gaziantep, the fee in the tariff determined by the Personal Data Protection Board may be charged.
Pursuant to Article 11 of the KVKK, data subjects (data owners – service recipients) have the right to:
(i) learn whether personal data relating to them is being processed, (ii) request information about it if their personal data has been processed, (iii) learn the purpose of processing their personal data and whether it is used in line with that purpose, (iv) know the third parties in Türkiye or abroad to which their personal data is transferred, (v) request the correction of their personal data if it has been processed incompletely or inaccurately, and request that the action taken in this context be notified to the third parties to which the personal data has been transferred, (vi) request the deletion or destruction of their personal data if the reasons requiring its processing no longer exist, even though it has been collected, processed and transferred in accordance with the provisions of the law and the relevant legislation, and request that the action taken in this context be notified to the third parties to which the personal data has been transferred, (vii) object to an outcome to their detriment arising from the analysis of the processed data exclusively by automated systems, and (viii) claim compensation for damage if they suffer loss due to the unlawful processing of their personal data.
Requests concerning the exercise of these rights may be submitted to us by personal data owners using the methods specified by Emek Hospital Gaziantep and under Law No. 6698.
The matters set out in this form may be subject to change in line with legal and technological developments.
If you have rights or requests that you wish to exercise under the articles above, you may send an e-mail signed with your secure electronic signature to info@emekhastanesi.com; or you may sign a file in “Word or PDF” format addressed to Emek Hospital Gaziantep with a secure e-signature and send it to info@emekhastanesi.com; or you may apply to the address of Medigap Sağlık Hizmetleri San. Tic. A.Ş. with a petition bearing your wet signature, sent by courier.
More information about the KVKK:
You can find detailed information about the KVKK at http://www.kvkk.gov.tr/.