Privacy Policy patients

Privacy Policy patients

This is a translation of the Danish original. In case of any divergence, the Danish version will prevail.

The processing of data
In connection with our investigation, diagnosis and treatment of you as a patient specialists Ursula Bentin-Ley and Hans Krog I/S / Dansk Fertilitetsklinik ApS will gather and process a range of personal information about you.

This privacy policy describes how medical specialists Ursula Bentin-Ley and Hans Krog I/S / Dansk Fertilitetsklinik ApS treats, use and disclose your personal information. 

Types of information
Medial specialists Ursula Bentin-Ley and Hans Krog I/S / Dansk Fertilitetsklinik ApS collects and processes the following types of personal information about you (to the extent it is relevant for just you):

General categories of personal data: 

• Name, address, email address, phone no., personal number (CPR number), gender, family relationships and social relationships, working relationships.

Special categories of personal data ( “sensitive personal data”): 

• Health information (e.g. Medical records, test results, tests, x-rays, scan results etc.), Sexual preference, race or ethnic origin, a picture of you for our electronic record. 

Purpose
We will process your personal data for the following purposes:

• Our investigation, diagnosis and treatment of you
• Preparation of medical reports
• Preparation of certificates for use by authorities, insurance companies, etc.
• Communication with reference to other healthcare personnel, physicians, hospitals and hospital laboratories
• Ordination of medication, including prescriptions
• Reporting to clinical databases
• Reporting of laboratory tests to hospital laboratories
• Settlement purposes
• Adhering to our obligations under applicable law, including the EU Data Protection Regulation, the Data Protection Act and other relevant health legislation, for example.
  • Documentation requirements
  • Compliance with the basic principles of processing of personal data and the legal basis for data processing 
  • Implementation and maintenance of technical and organizational security measures, including but not limited to preventing unauthorized access to systems and information, restricting the reception or distribution of malicious code, stopping the denial (denial-of-service attacks) and damage to computer systems and electronic communication systems 
  • Investigation of suspicion or knowledge about security breaches and reporting to the individuals and authorities
  • Handling of inquiries and complaints from data subjects and others
  • Handling of inspections and inquiries from regulators
  • Handling of disputes with data and third parties.
  • Statistical studies and scientific research

Volunteerism
When we collect personal information directly from you, you give the personal data voluntarily. You are not required to provide such personal information to us. The consequence of not providing us with the personal data will be that we cannot fulfil the above objects, including, in some cases, we cannot examine, diagnose or treat you.

Sources
In some cases we collect personal information about you from other health professionals, for example hospitals, referring physician or by looking into an electronic record system. We process the received information in accordance with this privacy policy.

Transfers of personal data
Dansk Fertilitetsklinik ApS and Speciallægerne Ursula Bentin-Ley og Hans Krog I/S have agreed on having joint data responsibility between the clinics and that the data subject can exercise his rights under the Data Protection Regulation and the Data Protection Act towards each of these clinics.

As far as necessary for the specific examination, diagnosis or treatment of you, your personal information will be disclosed and shared with recipients:

• Transmitting information to other health professionals if it is necessary for an actual treatment
• Transmitting information to other authorities, clinical databases, the Danish Vaccination Register, Agency for Patient Safety, Fælles Medicinkort, police, social authorities, Social Enterprise Security to the extent that there is an obligation to do so under applicable law.
• You as a patient have access to your own information (own-access)
• By referring patients, information on health topics will be disclosed to persons to which the reference is sent.
• When reporting laboratory samples, the tests are passed to the hospital laboratories.
• By submitting information in connection with the settlement of patient care, information is communicated to the regional accounting offices or to our internal accountant.
• When issuing prescriptions, information is disclosed to the pharmacies and Danish Medicines Agency via prescription server.
• In reporting to clinical databases, for instance the IVF Register, details of the treatment you have received is disclosed.
• Upon disclosure of discharge summaries, information is divulged to the referring physician and in some cases to the referring hospital
• In other cases, information may be disclosed to relatives or insurance companies.

Legal framework for the processing and transmission of personal data
The legal basis to collect, process and disclose your personal data are:

• For the use of the ordinary patient care, personal data are collected, processed and passed in accordance with data protection of Article 6 (1) (c) and (d), while the sensitive personal data are collected, processed and passed on in accordance with data protection Article 9 (2) (c) and H). 

• In addition, we are required to treat a range of personal information about you in the general treatment of patients pursuant to the Authorization Act Chapter 6, Ordinance on healthcare personnel records (record keeping Order) particularly §§ 5-10 and Health Act Chapter 9.

• Health information for further processing in the referral of patients, is disclosed under the provisions of Agreement on specialized medical help §§ 20-23 and the Danish Health Act.

• Reporting of laboratory tests for hospital laboratories takes place under the rules of Health guideline on the management of paraclinical investigations under the Authorization Act. 

• Information for billing for public patient care is forwarded once per month to the region’s clearinghouse in accordance with Agreement on Specialized Medical Care § 49 and the Health Act.

• Medication prescriptions are sent through an electronic prescription server under the provisions of the Health Act Chapter 42 and Executive Order on Prescriptions and Dose Dispensing of Medicines, especially chapter 3. 

• Clinical patient data are transmitted to clinical databases under the provisions of the Health Act §§ 195-196 and the Order on the reporting of information to clinical databases etc. Data can also be transmitted based on a specific consent from you as a patient.
• Discharge summaries, which is a brief summary of the patient’s medical history and treatment, are sent to the referring physician and in some cases to the referring hospital under the provisions of the Health Act Chapter 9.

• Your personal data are only transmitted to insurance companies with your prior consent cf. Data protection under Article 6 (1) (a) and 9 (2) (a). 

  Your personal information is solely disclosed for your relatives with your prior consent under the provisions of the Health Act § 43. 

• In deceased patients, certain personal data are transferred to the deceased’s next of kin, the deceased’s general practitioner and the doctor who had deceased in treatment under the provisions of the Health Act § 45.

Withdrawal of consent. If the processing of your personal data is based on consent, you have the right to withdraw your consent. If you revoke consent, it does not affect the treatment prior to withdrawal of consent, including disclosure based on prior consent.

Using data processors
Your personal data is processed and stored in our data processors that holds them on behalf of and as instructed by us. Our processors are currently

• Danish Medical Datacenter
• Ordenisagerne by Kristine Lund
• E-Conomic

Retention period
We store personal information about you, as long as we need to perform the above specified purposes. We are, however, according to the record keeping Order obliged to keep health related data for at least 10 years after the last record keeping to the Journal. There are cases where we are obliged to keep your personal information for longer, for example, as per the European Tissue Act (Act no. 273 of 1 April 2006 on the requirements for quality and safety in handling human tissues and cells, with the changes imposed of § 3 of law no. 534 of  June 17^th, 2008, § 2 of law no. 605 of  June 18^th, 2012, § 2 of law no. 653 of  June 12^th, 2013 and § 2 of law no. 1313 of  November 27^th, 2013, which requires data retention for 30 years), or in connection with a complaint or damages where the information in this case will be kept until the case is finally closed.

Your rights
You have – with legal restrictions – certain rights, including the right of access to your personal information, the right to change incorrect information, the right to erasure, the right to obtain limited information, the right to data portability, the right to object the processing of personal data in relation to automated individual decision making (“profiling”).

You also have the right to complain to a competent regulatory authority, including the Danish Data Protection Agency.

Contact
If you have any questions regarding the processing of your personal data or exercise of your rights, please contact us at the clinic.

Address information at the clinic: 
Speciallægerne Ursula Bentin-Ley and Hans Krog I/S
CVR no. 31716985 
Dansk Fertilitetsklinik ApS
CVR no. 41526696 
Seedorffs Vænge 2, 1st floor 
DK – 2000 Frederiksberg 
Date: August  31^st, 2020