OP. DR. YUSUF ÜNAL CLINIC
INFORMATION NOTICE ON THE PROCESSING OF PERSONAL DATA
As Dr. Yusuf Ünal Clinic, we prioritize the right to privacy, which is also a patient right, in our outpatient clinic activities and/or teleconsultation services. With this awareness, we apply the necessary procedures to process and safeguard the personal data transmitted to us by individuals associated with our clinic/services, including patients, their relatives, clients, and employees, in compliance with the Constitution of the Republic of Turkey, international conventions to which our country is a party concerning human rights, and relevant legislation, primarily the Law on Protection of Personal Data No. 6698 (“KVKK”).
In compliance with the KVKK and as the Data Controller, we adhere to the regulations outlined on this page regarding the processing of your personal data. Your personal information will be appropriately recorded, securely stored, and kept up-to-date within the limits set by the law. In certain circumstances allowed by the legislation, your data may be disclosed or transferred to third parties. Additionally, it may be categorized, anonymized, de-identified, or completely erased, as required, to ensure compliance with the KVKK. All these processes are carried out in connection with our operational and service objectives, and in a proportionate manner.
İşbu Privacy Notice serves as informative documentation, providing clarification as the “Data Controller” regarding the processing of your personal data obtained during the provision of our healthcare services. It outlines the types of personal data collected, the methods of collection, usage, protection, disclosure, deletion, and more.
Dr. Yusuf Ünal, acting as the data controller, provides the following information regarding the processing of your personal data;
HOW WE COLLECT AND PROCESS PERSONAL DATA
Within the context of our healthcare services/consultancy services, we gather a variety of information from our patients, and/or, when necessary, from their legal representatives, as well as from our clients and employees, along with relevant third parties associated with our clinic/services. The collection of such information strictly adheres to the principles and requirements of data processing as outlined in the Personal Data Protection Law No. 6698 (“KVKK”).
Regarding sensitive personal data, specifically the health data of individuals, processing can take place without explicit consent, provided it serves the purposes of safeguarding public health, preventive medicine, medical diagnosis, treatment, and care services, as well as the planning and management of healthcare services and financing, under the obligation of confidentiality imposed on relevant individuals or authorized institutions and organizations. Furthermore, it is important to emphasize that all types of sensitive personal data, irrespective of their nature, can only be processed in compliance with the KVKK, subject to the implementation of sufficient measures as defined by the aforementioned legislation.
The personal data shared with us within the scope of our clinic activities/Consultancy Services, facilitated by Dr. Banu Çiftçi, is acquired, recorded, stored, modified, and reorganized using both automated and non-automated methods. These processes serve the purposes of protecting public health, preventive medicine, medical diagnosis, treatment and care services, as well as the planning and management of healthcare services and financing. The data collection encompasses a wide range of channels, including the internet website, surveys, social media applications, such as social responsibility initiatives, and various verbal, written, visual, or electronic mediums. Additionally, consultation hotlines/call centers, as well as personal interactions at the clinic, further contribute to the gathering of personal data. It is crucial to underscore that any operation involving personal data, as defined within the scope of the KVKK, is classified as “the processing of personal data”.
Furthermore, it should be noted that during your utilization of our consultation hotline or internet page for the purposes of information acquisition, appointment scheduling, complaints, or other related matters, as well as during your physical presence at our clinic or your navigation of our website, the processing of your personal data may occur.
WHICH PERSONAL DATA DO WE COLLECT?
In relation to the provision of healthcare services or the legal relationship with our clinic/Banu Çiftçi (such as employees, consultants, etc.), the personal data we collect may vary but include the following examples for the purposes outlined in Section 3:
- Identity information: This includes personal details such as name, surname, identification documents (e.g., ID card, passport, driver’s license), Turkish Identification Number (T.C. Kimlik Numarası), passport number, temporary Turkish Identification Number, place and date of birth, marital status, gender, insurance or patient protocol number, and other relevant identification data.
- Contact information: This pertains to details like address, telephone number, email address, and other communication data acquired through interactions with our clinic, including consultations, hotline calls, emails, letters, and other forms of communication.
- Financial information: This encompasses financial data such as bank account number, IBAN, credit card information, billing details, and other relevant financial information.
- Healthcare-related data: This involves personal health information obtained during the provision of healthcare services, including laboratory and test results, examination data, prescription details, and other pertinent health and sexual life-related data resulting from medical diagnosis, treatment, and care services.
- Biometric and other data: This category includes photographs associated with the provision of healthcare services, as well as images used for administrative purposes within the personnel files of clinic employees.
- Remote consultation data: In the case of receiving counseling services through remote connection systems, personal data such as identity information, contact details, health data, genetic information related to sexual life, as well as visual and auditory data, and records of consultations/dossiers prepared by the consultant may be collected.
- Employment-related data: If applying for a position at the clinic or being an employee or consultant, personal data such as curriculum vitae and other relevant information may be collected within the scope of the employment contract and personnel files, including data related to family members.
It is important to note that the collection of personal data adheres to the principles and requirements set forth in the Law on Protection of Personal Data No. 6698 (KVKK). The collected data encompasses both special and general personal information shared through various channels with our clinic/Banu Çiftçi.
THE PURPOSES AND LEGAL GROUNDS FOR PROCESSING YOUR PERSONAL DATA
Paylaştığınız hem özel nitelikteki kişisel veriler hem de genel nitelikteki kişisel veriler;
The personal data, both of a sensitive nature and of a general nature, that you disclose;
- Compliance with our legal obligations as stipulated in the Health Services Basic Law No. 3359, Decree Law No. 663 concerning the Organization and Duties of the Ministry of Health and its Affiliated Institutions, the Regulation on Outpatient Diagnosis and Treatment in Private Healthcare Institutions, the Regulation on Personal Health Data, and other pertinent regulations;
- Preservation of your data within the framework of contractual responsibilities;
- Retention of information pertaining to your healthcare data that must be preserved according to the applicable legislation;
- Sharing of requested information with the Ministry of Health and other public institutions and organizations as required by the relevant legislation;
- Protection of public health and the execution of preventive medicine, medical diagnosis, treatment, and care services;
- Provision of information to prosecutors, courts, and relevant public officials in matters related to public safety and legal disputes, upon request and in accordance with legal provisions;
- Provision of healthcare and counseling services, encompassing preventive healthcare;
- Planning and management of healthcare service financing;
Provision of Video Counseling Services.
- In order to safeguard data integrity, comprehensive technical and administrative precautions will be undertaken,
- Effective planning and management of the clinic’s internal operations, continuous service enhancement, rigorous analysis, proactive risk mitigation, and thorough evaluation of quality processes,
- Prompt communication regarding scheduled appointments upon your booking,
- Proactive monitoring and prevention of unauthorized activities and potential abuses, Issuance of professional invoices in exchange for the services rendered;
- Thorough verification of individual identities, Responsive handling of all inquiries and complaints pertaining to our healthcare services,
- Systematic measurement and continual improvement of patient satisfaction, prioritizing employee training and development initiatives,
- Reliable facilitation of pharmaceutical and medical equipment procurement,
- Adherence to rigorous risk management protocols and a commitment to ongoing quality improvement efforts,
- Information dissemination via marketing, media, and communication channels, meticulous design and delivery of bespoke content to convey tangible and intangible benefits through web and mobile platforms, as well as the execution of public awareness initiatives,
- Furthermore, to ensure seamless implementation of our clinic’s human resource policies, employee data will be processed in compliance with the Labor Law, pertinent employment and social security regulations, while concurrently striving to boost performance levels, employee satisfaction, and fostering a safe and harmonious work environment,
These objectives shall serve as the basis for data processing.
By entrusting your personal data, it may be securely transferred and stored in both digital and physical formats within the physical archives and/or information systems of our clinic, under the umbrella of Yusuf Ünal, and/or affiliated contractual entities.
REGARDING THE CONDITIONS OF PERSONAL DATA PROCESSING AND MATTERS RELATED TO EXPLICIT CONSENT
In compliance with the provisions stated in Articles 5 and 6 of the KVKK, it is mandated that “personal data cannot be processed without the explicit consent of the data subject.” Nevertheless, certain exceptions have been enumerated as follows:
- When there is a clear provision for such processing in relevant laws.
- In cases where the data subject, due to actual impossibility, is unable to express their consent or when their consent is not legally recognized, but it is essential for the protection of their own or another person’s life or physical integrity.
- When processing personal data directly pertains to the establishment or performance of a contract, as long as it is necessary for the contract parties.
- When the data controller must process the personal data to fulfill their legal obligations.
- When the data subject has already made the data publicly available.
- When data processing is indispensable for establishing, exercising, or protecting a legal right.
- When the processing of personal data is imperative for the legitimate interests pursued by the data controller, as long as it does not unduly infringe upon the fundamental rights and freedoms of the data subject.
However, it is important to note that these exceptions do not apply universally and unconditionally to all special categories of personal data. Specifically, personal data concerning race, ethnicity, political opinions, philosophical beliefs, religion, sect, appearance, association or union membership, health, sexual life, criminal convictions, security measures, as well as biometric and genetic data, are classified as special categories of personal data. Processing such data without the explicit consent of the data subject is strictly prohibited, unless otherwise stipulated by legislation. However, for personal data other than health and sexual life, explicit consent is not mandatory unless specified by applicable laws.
Personal data related to health and sexual life may only be processed without explicit consent by individuals or authorized institutions and organizations bound by confidentiality obligations, provided that the processing is necessary for safeguarding public health, preventive medicine, medical diagnosis, treatment, and care services, as well as the planning and management of healthcare services and financing.
Consequently, in the context of our provision of preventive healthcare and related services, we undertake the processing of our patients’ health data and, when applicable, their sexual life data, without seeking explicit consent.
Moreover, in cases where it is regulated by law, we also process special categories of data other than health and sexual life without obtaining explicit consent.
For all other special categories and other types of personal data, we carry out their processing exclusively with explicit consent.
In summary, we ensure that your personal data is processed in accordance with the law and principles of integrity, encompassing relevance to processing purposes, limited and proportionate handling, accuracy and currency, and specific, transparent, and legitimate objectives.
WHAT IS THE PROCESSING PERIOD FOR YOUR PERSONAL DATA?
The processing of your personal data will be carried out in compliance with the relevant legislation, such as the KVKK (Personal Data Protection Law), and other obligatory temporal intervals specified by pertinent regulations (including statutory limitation periods and periods associated with legitimate interests), provided that the aforementioned legitimate objectives remain in effect.
PERSONS AND ORGANIZATIONS TO WHICH YOUR PERSONAL DATA MAY BE TRANSFERRED
- We have the authorization to transfer your personal data to institutions and organizations permitted by laws such as the 359th Law on Basic Health Services, Decree Law No. 663 on the Organization and Duties of the Ministry of Health and its Affiliated Institutions, Regulation on Outpatient Diagnosis and Treatment Private Healthcare Institutions, Regulation on Personal Health Data, and other relevant regulations. These entities include the Ministry of Health and its sub-units, security forces under the Ministry of Interior, prosecution authorities, courts, other authorized official bodies, private insurance companies, our legal representatives, consultants, auditors, business partners, laboratories, centers, and other third parties with whom we collaborate for healthcare services. This data transfer is necessary for the smooth operation of our activities.
WHAT SHOULD YOU DO IF YOUR PERSONAL INFORMATION CHANGES?
In the event of any modifications in your personal data, it is necessary to notify us in order to facilitate the update of our records. Furthermore, in accordance with our established procedures, we may seek your consent to validate the precision and currency of your personal information, including contact and address details.
PERSONAL DATA OF CHILDREN
Regarding the personal data of individuals who have not reached the age of 18 within the scope of Turkish laws, we have the ability to process such data with the consent of the minor’s parent or legal guardian in situations where explicit consent is required.
RIGHTS OF THE PERSONAL DATA OWNER UNDER LAW NO. 6698 ON THE PROTECTION OF PERSONAL DATA
In accordance with Article 11 of Law No. 6698 on the Protection of Personal Data (KVKK), individuals are entitled to the following rights:
- The right to be informed about whether their personal data is being processed.
- The right to request information about the processing of their personal data if it has been processed.
- The right to ascertain the purpose of the processing of personal data and its conformity with the intended purpose.
- The right to know the third parties, both domestically and internationally, to whom their personal data has been disclosed.
- The right to request the rectification of incomplete or inaccurate personal data.
- The right to request the erasure or destruction of personal data in accordance with the conditions specified in Article 7 of the KVKK. (It should be noted that the right to erasure will be evaluated in accordance with the Regulation on Personal Health Data, as there may be an obligation to retain personal health data within the scope of legislation.)
- The right to request that any rectification, erasure, or destruction of personal data be communicated to third parties to whom the data has been disclosed. (It should be noted that the right to erasure will be evaluated in accordance with the Regulation on Personal Health Data, as there may be an obligation to retain personal health data within the scope of legislation.)
- The right to object to any decision resulting from the automated processing of personal data that may have a negative impact on the individual.
- The right to seek compensation for any damages incurred as a result of the unlawful processing of personal data.
These rights can be exercised by individuals by making a formal application in accordance with the applicable legislation.
In addition, in the event that we obtain your consent to process your personal data for a specific purpose, such as a research project, or to engage in informative promotional activities, it is important to note that you have the right to withdraw your consent at any given time.
To exercise the aforementioned rights, you are required to complete the “Application Form in accordance with the Law on the Protection of Personal Data” available on the website www.yusufunal.com. This form necessitates the provision of your identification details, a clear indication of the specific right you wish to exercise, and a comprehensive explanation of your request. Subsequently, you have the option of submitting the completed form in person, directly to the address “Unimed Center – Teşvikiye Mah. Hakkı Yeten Cad. No:19 Kat:1, 34365 Nişantaşı/İstanbul,” or dispatching it via notary or registered mail, explicitly specifying “Personal Data Information Request.” Furthermore, alternative means of communication, such as the email address info@yusufunal.com or the telephone number 0212 824 01 14, can be utilized as necessary.
It should be noted that during the application process, we reserve the right to request the presentation of identification documents in order to authenticate your identity.
Within the parameters of this framework, your applications will be addressed and resolved within a maximum period of 30 days. It is important to emphasize that these applications are exempt from any charges. However, in the event that the processing entails additional costs in accordance with Article 13, paragraph 2 of the law, the prescribed fee stipulated by the relevant regulatory body will be incurred and collected by our clinic, under the name of Yusuf Ünal.