Preamble In the context of your treatment by the Dentego Center, your personal health data are collected and processed on the legal and lawful basis of providing care and making medical diagnoses in accordance with Articles 6 and 9 of the General Data Protection Regulation […]
As part of your treatment by the Dentego Center, your personal health data are collected and processed on the legal and lawful basis of providing care and establishing medical diagnoses in accordance with Articles 6 and 9 of the General Regulation on the Protection of Personal Data (RGPD) n°2016/679 of April 27, 2016, in application since May 25, 2018. This purpose of processing personal health data falling under a provision provided by the regulatory provisions does not require the collection of your consent. However, any other use of your personal data for a purpose other than that described above requires the collection of your free, specific, informed and unambiguous consent (your agreement). The objectives of the personal data protection policy are to:
- To inform you about the nature of a new processing of your personal data and its modalities of realization;
- To present to you the personal data protection, security and confidentiality commitments of the Dentego Centre;
- Collect your consent on the basis of this information.
If you do not wish to give your consent, you will continue to access Dentego Center’s services in the normal way without any change in your care or use of the Center’s current services.
- The purpose of the data processing and use of the personal data concerned
In order to improve the services provided, the Dentego Centre wishes to set up a personalized follow-up of your care file. The purpose of this follow-up is to offer you services dedicated to your personal use of the Centre’s services. In this respect, the Centre wishes to use your personal data for research purposes in order to define performance and quality indicators that will enable it to offer you additional services free of charge and/or to improve existing services. The results of these studies will not contain any personally identifiable information. As a continuation of this processing of personal data and in order to provide you with quality services, Dentego will use your personal data to send you satisfaction questionnaires.
- The personal data concerned
The personal data concerned are only those strictly necessary for the purpose described in point 1 in the name of the principle of data minimization (Article 5, c) of the RGPD). Thus, only the personal data below will be used and processed for the purpose in question:
- Surname (birth and use) and First name;
- Date of birth ;
- Postal address of your residence;
- Reason for the appointment with the practitioner: predefined reason on the Doctolib platform (first dental consultation / Child: first dental consultation / Adult: first orthodontic consultation / Child: first orthodontic consultation / first implantology consultation / estimate for prosthesis – implant / dental emergency) ;
- Frequency of appointments;
- Appointment history.
No personal health data related to your pathology following your examination by the practitioner is concerned by this new processing of your personal data.
- Control of access to personal data concerned in the context of the purpose referred to in 1
The access to your personal data concerned as described in 2 is limited to a list of authorized persons. This list is validated by the Data Protection Officer of the Dentego Centre. Access is limited to the IT department in charge of managing the database. No other staff member of the Dentego Centre is authorized to access this database containing your personal data dedicated to the purpose mentioned in 1.
- How the personal data concerned is hosted
The hosting of your personal data has been entrusted by the Dentego Center (the data controller) to the Microsoft Corporation (the hosting subcontractor). The server hosting your personal data is located within the European Union in accordance with regulatory requirements: Amsterdam, the Netherlands. Dentego Centre is committed to protecting your data in accordance with applicable laws and regulations. The Dentego Centre undertakes to implement all appropriate and sufficient technical and organisational security measures to guarantee the confidentiality and security of the personal data concerned by the processing referred to in point 1, in particular with regard to its subcontractors and its staff.
- Retention and sharing of data
- Duration of retention of your personal data
The duration of data retention is strictly limited to the period necessary for the purpose of the data processing concerned, in accordance with the laws and regulations in force. As part of the personalized follow-up of your care file, the services that will be offered by the Center in the future will be linked to the management of your administrative file. Thus, if you consent to the processing referred to in 1, your personal data referred to in 2 will be kept in the same way as your active administrative file with the Dentego Centre.
- Sharing of your personal data
The management of your personal data within the framework of the personalised follow-up of your care within the Dentego Centre is not shared with third parties. Only the sending of satisfaction questionnaires requires the intervention of a third party company, “verified opinions”, whose confidentiality policy has been updated following the European regulation on data protection: https: //www.avis-verifies.com/index.php?page=mod_regles_confidentialites. This company is responsible, on behalf of Centre Dentego, for sending you the emails containing these questionnaires. This subcontractor only receives the following personal data:
- First name, Last name ;
- Email address;
- Appointment date;
- Unique file reference/ID;
- Dental Center.
Personal data is kept by ” Avis Vérifiés ” for a period of 18 months. No transfer of your personal data outside the European Union is made.
- Exercising your rights
The Dentego Center is committed to guaranteeing the respect of your rights in terms of personal data protection. In accordance with the law on data processing, files and freedoms of January 6, 1978 as amended, as well as the European regulation on the protection of personal data of April 27, 2016, except in the case of limitation, your rights regarding data are:
- Right of access: the right to be informed and to request access to the personal data that Centre Dentego processes ;
- Right of rectification: the right to request that your personal data be amended or updated if it is inaccurate or incomplete;
- Right to erasure (right to be forgotten): the right to request the definitive deletion of your personal data processed for the purpose referred to in 1;
- Right to limitation of processing: the right to request to temporarily or permanently stop the processing of all or part of your personal data;
- Right to object: the right to refuse at any time the processing of your personal data;
- Right to data portability: the right to request a copy of your personal data in electronic format and the right to transmit this personal data for use by a third party service;
- Right not to be subject to automated decision making: the right not to be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similar significant effect.
At any time and without any particular cost, you may withdraw your consent. In such a case, the Dentego Centre undertakes to ensure the effective and definitive deletion of your personal data used in the context described herein, and to notify you of the completion of this action within a maximum of one month following receipt of your request. This withdrawal of consent will have no consequence on the continued proper functioning of your administrative file with the Dentego Center.
- Your interlocutors
All the medical, nursing and administrative staff of the Dentego Center are at your disposal and are committed to providing you with the information necessary to exercise your rights. A dedicated contact person within the Dentego Centre, the Data Protection Officer (hereinafter “DPO”), is at your disposal for the exercise of your rights or for requests for information concerning the personal data processed in the context of the purpose referred to in 1. The Data Protection Officer will independently ensure the protection of your personal data.
You can write to the Data Protection Officer (DPO) of the Dentego Centre to exercise your rights
- By mail: Dentego Center Data Protection Delegate – 23 Bis rue Barthelemy Danjou, 92100 Boulogne-Billancourt.
- By email : email@example.com
In the event of a complaint, you may choose to contact the French supervisory authority responsible for compliance with the rules on the protection of personal data, the Commission Nationale de l’Informatique et des Libertés (CNIL):
- By mail: 3 Place du Fontenoy TSA 80715, 75334 Paris, Cedex 07
- By internet : https://www.cnil.fr/fr/plaintes/