The Law on the Protection of Personal Data No. 6698 (KVKK), 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 the Processing and Protection of Personal Health Data (Regulation), the regulations of the Ministry of Health, and other relevant legal provisions require that your Personal Data, including sensitive personal data, is collected and processed in accordance with the law while utilizing all the services we provide. This Information Text outlines the information provided by Dr. Fatma Horasan's Clinic to you.
As the Data Controller, Dr. Fatma Horasan's Clinic can record, store, update, share, transfer, and classify your Personal Data as described in this Information Text, and process it in ways specified in KVKK and other relevant regulations, including sharing with third parties (relatives of the service recipient and/or public and/or private legal entities where the service recipient is an employee/insured, other public and/or private legal entities, third parties with whom we cooperate or work to carry out activities subject to the regulations applicable to our clinic) in cases where permitted or required by legislation or agreements.
Your health data is classified as sensitive data under KVKK and cannot be processed without the explicit consent of the data subject. However, health data may be processed without explicit consent by persons or authorized institutions and organizations under a confidentiality obligation for purposes such as protecting public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing.
Your Personal Data is collected by Dr. Fatma Horasan's Clinic through written (patient identification form, patient information and consent form, etc.), verbal, visual, electronic means, email, and other channels for purposes including public health protection, preventive medicine, medical diagnosis, treatment and care services, and planning and managing health services and financing.
I. PROCESSED PERSONAL DATA
Including but not limited to your health data, your personal and sensitive personal data: name, surname, T.C. Identity number and/or passport number and/or temporary T.C. Identity number, place and/or date of birth, marital status, gender, health insurance, occupation, insurance card number, workplace registration and/or patient identification number, other identifiable identity data; address, phone number, email address and other communication data; voice call recordings maintained by customer representatives and/or patient services in accordance with call center standards, and personal data obtained when you contact us via email, letter, or other means; financial data such as bank account number, IBAN number, credit card information, billing and invoice details; data related to special health insurance and information of payer institutions like the Social Security Institution for financing and planning of health services; patient medical reports, diagnosis data, biometric and genetic data, laboratory results, test results, examination data, doctor’s analyses and comments, appointment information, prescription details, including but not limited to all health data obtained during or as a result of medical diagnosis, treatment, and care services; your feedback such as surveys, thank you notes, complaint letters, satisfaction results; images obtained from continuous camera recordings in shared areas of our Clinic; health data sent and/or entered through all of Dr. Fatma Horasan's Clinic's websites and online services, IP address, cookies, and other personal data; personal data related to job applications, including CVs, and any other personal data related to your service contract, will be processed by Dr. Fatma Horasan's Clinic in a manner that is related to, limited, and proportionate to the purpose for which the information was collected.
II. PURPOSE OF PROCESSING PERSONAL DATA
Dr. Fatma Horasan's Clinic may process your Personal Data for the following purposes:
To fulfill our legal obligations under 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 Law on the Protection of Personal Data No. 6698, the Regulation on the Processing and Protection of Personal Health Data, and other relevant regulations,
To plan and manage the internal operations and daily practices (treatments) of our Clinic,
To protect public health, carry out preventive medicine, medical diagnosis, treatment, and care services, and plan and manage health services and financing,
To conduct special promotional and informational activities for you and ensure your benefit,
To maintain information related to health data that must be kept according to relevant legislation,
To notify you about appointments, provide information, and/or remind you of appointments if you make one,
To carry out risk management and quality improvement activities,
To meet legal and regulatory requirements,
To share and respond to information with the Ministry of Health and other public institutions and organizations as required by the legislation,
To issue invoices for the services we provide,
To comply with internal policies and principles,
To measure and enhance patient satisfaction following the receipt of health services,
To analyze your use of health services and store health data to improve and enhance the services we provide, respond to questions or complaints about our services,
To share requested information with insurance companies and other affiliated institutions/organizations for the financing of health services, and to verify identities,
To contact you for informational and campaign purposes related to the services provided by Dr. Fatma Horasan's Clinic, and for purposes including but not limited to medical diagnosis, treatment, and care services, development and improvement of health services, planning and management of health services and financing, increasing patient satisfaction, research, and related reasons. The Personal Data obtained and processed in accordance with the relevant legislation may be kept in physical archives and/or transferred to digital environments and maintained in both digital and physical forms.
III. CASES WHERE EXPLICIT CONSENT IS NOT REQUIRED FOR PROCESSING PERSONAL DATA
Health data (Sensitive Personal Data) is generally prohibited from processing without explicit consent, except in cases where it is processed based on legal grounds or the data subject's consent. There are exceptions to the processing of sensitive personal data without explicit consent. In the following cases (KVKK Art. 5 and Regulation Art. 7), Personal Data may be processed without explicit consent:
When explicitly provided for by laws,
When you cannot express your consent due to physical impossibility or in situations where legal validity is not recognized for your consent, and the processing of Personal Data is mandatory for the protection of your life or physical integrity or that of another person,
When it is directly related to the establishment or performance of a contract, and processing Personal Data is necessary for the parties to the contract,
When it is mandatory for fulfilling a legal obligation,
When Personal Data has been made public by you,
When processing Personal Data is necessary for the establishment, exercise, or protection of a right,
Without harming your fundamental rights and freedoms, when it is necessary for the legitimate interests of Dr. Fatma Horasan's Clinic,
When all protection mechanisms are established by the state.
Data necessary for protecting health, medical diagnosis, treatment, or the management of health services can be processed if done by individuals subject to confidentiality obligations.
Additionally, your sensitive personal data related to health and sexual life can be processed without explicit consent by Dr. Fatma Horasan's Clinic for purposes of public health protection, preventive medicine, medical diagnosis, treatment and care services, and planning and management of health services and financing.
Sensitive Personal Data related to the race, ethnicity, political opinions, religious or philosophical beliefs, sect, or other beliefs, dress, association, foundation, or union memberships may be processed without explicit consent in cases foreseen by laws.
Personal Data publicly disclosed by the data subject may be processed without explicit consent.
In the processing of sensitive personal data, if the Personal Data Protection Board determines that sufficient measures have not been taken, even if the data subject provides explicit consent, it may be decided not to process the data.
TRANSFER OF PERSONAL DATA
In accordance with KVKK and relevant health legislation, necessary technical and administrative measures will be taken to ensure the appropriate level of security, and your Personal Data may be transferred to domestic and international third parties in line with the purposes specified in Section II; including individuals/institutions/organizations permitted or required by the Basic Law on Health Services No. 3359, Decree Law No. 663, Law on the Protection of Personal Data No. 6698, Regulation on the Processing and Protection of Personal Health Data, and other relevant legislation; special insurance companies, the Ministry of Health and its affiliated units, the Social Security Institution, the General Directorate of Security and other law enforcement agencies, the General Directorate of Population, the Turkish Pharmacists Association, courts and all judicial authorities, central and other third parties, including but not limited to private and public sector institutions/organizations where legal obligations are fulfilled.
In case of a legal obligation or an obligatory situation, your Personal Data will be shared with legally authorized institutions, courts, and other public authorities.
Necessary precautions are taken to protect your Personal Data, and measures are in place to prevent any unauthorized access and ensure compliance with data protection regulations.
RIGHTS OF THE DATA SUBJECT
As a data subject, you have the following rights under Article 11 of KVKK:
1. To learn whether your Personal Data is processed or not,
2. To request information regarding your Personal Data if it has been processed,
3. To learn the purpose of processing your Personal Data and whether it has been used in accordance with its purpose,
4. To know the third parties to whom your Personal Data is transferred at home or abroad,
5. To request correction of your Personal Data in case of incomplete or incorrect processing, and to request notification of the operations made to the third parties to whom your Personal Data has been transferred,
6. To request the deletion or destruction of your Personal Data in case the reasons for its processing no longer exist, and to request notification of the operations made to the third parties to whom your Personal Data has been transferred,
7. To object to any unfavorable result arising from the analysis of your processed Personal Data exclusively through automated systems,
8. To request compensation for damages caused by the unlawful processing of your Personal Data.
In accordance with Article 13 of KVKK, you can apply to Dr. Fatma Horasan's Clinic regarding your rights listed above. Your applications will be evaluated and concluded within 30 days. Your request should include your name, surname, Turkish Republic ID number, address, phone number, email address, and the subject of your request. You can make your application in writing or electronically, depending on the methods specified by KVKK. If your request requires a fee, you may be asked to pay the specified fee.
AMENDMENTS TO THE INFORMATION TEXT
Dr. Fatma Horasan's Clinic reserves the right to update this Information Text periodically in accordance with changes in applicable legislation and regulations. The updated version of the Information Text will be available on our website, and you will be notified of any significant changes.
CONTACT INFORMATION
For any questions or concerns regarding this Information Text or the processing of your Personal Data, please contact:
Dr. Fatma Horasan's Clinic
Address: [Your Address]
Phone: [Your Phone Number]
Email: [Your Email Address]