Introduction and scope
At Elit Polikliniği (‘Clinic’ or ‘data controller’), we attach great importance to protecting the personal data of our patients, patients’ relatives, visitors and employees. This Privacy Notice has been prepared pursuant to Article 10 of Law No. 6698 on the Protection of Personal Data (‘KVKK’) and the Communiqué on the Procedures and Principles to Be Followed in Fulfilling the Obligation to Inform, to explain how your personal data are processed.
As a healthcare provider, our activities are subject to the KVKK and the applicable healthcare legislation, including the regulations listed below. Your personal data are processed in accordance with the obligations set out in this legislation:
- Basic Law No. 3359 on Health Services,
- Decree-Law No. 663 on the Organisation and Duties of the Ministry of Health and its Affiliated Institutions,
- Regulation on Private Hospitals and Regulation on Private Healthcare Institutions Providing Outpatient Diagnosis and Treatment,
- Regulation on Personal Health Data,
- Other relevant legislation and regulations of the Republic of Türkiye Ministry of Health.
Categories of personal data processed
Depending on the nature of the service we provide, we may process the following categories of personal data:
- Identity Data
- Information that identifies or can identify you, such as your first name, surname, Republic of Türkiye identity number, date of birth and gender.
- Contact Data
- Information that enables us to contact you, such as your phone number, email address and postal address.
- Location Data
- Information about your location in connection with receiving a service or visiting the clinic.
- Family / Next-of-Kin Data
- Identity and contact details of an emergency contact, companion or legal representative.
- Physical Premises Security
- CCTV recordings and, where necessary, access records such as fingerprints, used to protect our clinic and patients.
- Transaction Security Data
- Information-security data such as IP addresses, cookie records and system-access information.
- Special-Category Personal Data
- Health data (examination, diagnosis, test, treatment and procedure records, and imaging results) and data concerning sex life. These data are protected with the highest level of confidentiality and security measures.
Purposes and legal grounds for processing
Your personal data are processed under the conditions specified in Articles 5 and 6 of the KVKK, the Regulation on Personal Health Data and applicable healthcare legislation, primarily for the following purposes:
- Providing medical diagnosis, treatment and care services,
- Providing preventive medicine and medical assessment services,
- Carrying out activities to protect public health,
- Planning and managing healthcare services and their financing,
- Managing appointments, calls and communications with patients,
- Fulfilling record-keeping, reporting and notification obligations arising from applicable legislation,
- Ensuring clinic and patient safety and following legal proceedings.
The legal grounds for these purposes are compliance with a legal obligation, entering into or performing a contract, the legitimate interests of the data controller, and the conditions for processing special-category data explained below.
Processing conditions beyond explicit consent
Under Article 5(2) of the KVKK, your personal data may be processed without explicit consent where processing is expressly provided for by law; is necessary to enter into or perform a contract; is necessary for the data controller to comply with a legal obligation; or is necessary for the data controller’s legitimate interests, provided that the fundamental rights and freedoms of the data subject are not harmed.
Processing of special-category data
Your special-category personal data concerning health and sex life may be processed without explicit consent by persons bound by confidentiality or by authorised public institutions and organisations for the protection of public health, preventive medicine, medical diagnosis, treatment and care services, and the planning and management of healthcare services. In other circumstances, special-category data are processed only on the basis of your explicit consent.
Rights of the data subject (KVKK Art. 11)
Under Article 11 of the KVKK, you have the following rights regarding your personal data by applying to the data controller:
- To learn whether your personal data are being processed,
- To request information if your personal data have been processed,
- To learn the purpose of processing and whether the data are used in accordance with that purpose,
- To know the third parties in Türkiye or abroad to whom the data are transferred,
- To request correction if the data have been processed incompletely or inaccurately,
- To request deletion or destruction under the conditions set out in the KVKK,
- To request notification of correction, deletion or destruction to third parties to whom the data have been transferred,
- To object to a result arising against you through the analysis of processed data exclusively by automated systems,
- To claim compensation if you suffer damage because your personal data have been processed unlawfully.
How to submit a request
You may submit requests concerning your rights under Article 11 of the KVKK to the data controller through the channels below, together with information verifying your identity. Requests are concluded as soon as possible and no later than thirty days, depending on their nature.