Patient Portal

In accordance with EU Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data; Organic Law 3/2018, of December 5, on data protection and digital-rights guarantees; and Law 41/2002, of November 14, regulating patient autonomy and patient rights and obligations regarding clinical information and documentation, all patients, users of the services rendered on these premises, and the general public are hereby informed of the following:

Introduction

This document contains the privacy policy of the health centers of Grupo Hospitalario Quirónsalud regarding the personal data processing of patients receiving treatment from the aforementioned business entity and/or the individuals acting on behalf of these patients.

Patients may address any issues or questions regarding this matter to the Quirónsalud Hospital Group Data Protection Officer, who may be reached via post at Calle Zurbarán, 28, 28010 Madrid. The Data Protection Officer may also be reached via email at DPO@quironsalud.es.

Who is the data controller?

Data Controller is the company that holds ownership over the facility where the care is rendered:

What personal information do we process and what is the source of this information?

Based on the relationship you enter into with us, we may process the following personal data:

• Identification data and Contact details of patients or their representatives (including signature, image, health-service card, and social security number or mutual benefit association number);
• Biometric data of the patients (facial images);
• Health-related information appearing in patient medical records;
• Personal characteristics and demographic attributes; and
• Transactional data (payments of any nature, including transfers and debits).
• Location data (Geolocation) of patients through various channels, depending on the service and the device used, including GPS (through the settings of your mobile device), Bluetooth or Wi-Fi connections. The collection of location (geolocation) information takes place in the background on the device, even when the service is not used, as long as the permission granted by the patient allows such collection.

The data may come from the Data Subject (the patient) or from your legal or volunteer representative and/or care professionals.

Why do we process your personal information?

Data Controller may process personal data for the following purposes:

1. Delivery of health care: your personal information is processed for the purposes of providing you the health care you need as well as to appropriately manage the health services and carry out administrative tasks required for the provision of care, as in the following examples:
   • To send appointment reminders;
   • To issue proof-of-hospital-visit documents for family members or others with ties to you and who may request such a document in adherence of applicable regulations;
   • To communicate with another health center when instructed to do so by the patient;
   • To process any and all incidents or claims filed by the individual using the service and/or you, the patient;
   • To administer surveys intended to gather your opinion of the care delivered to you; such surveys shall be used exclusively to improve and develop our care services and management activities; and
   • To provide the services offered via the Quirónsalud Patient Portal: personal information pertaining to patients who register as users of the Portal may be processed for the purposes of accessing and using the tool.
   • Sending information and activities for health promotion and prevention.
   • Biometric data such as facial images will be processed to measure the heart rate, respiratory rate and blood pressure of the patient.
2. Synchronization with the mobile health applications of the mobile device: if you expressly consent, you can consult from the Patient Portal the physical activity and sleep habits data recorded in your mobile applications. In the event that you synchronize with Google, the use and transfer to any other application of information received from Google APIs complies with the Google API Services User Data Policy, including limited use requirements.
3. Scientific research: your data may be processed for scientific purposes in compliance with specific regulations governing such processing.
4. Procedures: for anonymization and pseudonym use: For scientific or statistical research purposes, your data may be subjected to certain procedures to make them unidentifiable or so that they can no longer be linked to any party in the absence of additional information appearing separately.
5. Processing of information requests, complaints, suggestions, grievances, and the exercise of data-protection rights, etc.: your data will be processed to fulfill the request by any means necessary, including telephone calls and/or electronic means.
6. Compliance with legal obligations: in order to comply with applicable legal obligations, it may be necessary to process personal information. Specifically, these obligations may be related to compliance with legislation on data protection, taxation, health, etc.
7. Drawing up executing the contract: personal information is processed to manage the contractual relationship with the patient.
8. Video surveillance: certain health facilities have a video surveillance system that takes real-time footage of individuals who use the facility’s services. These data are processed for the sole purpose of safety and to monitor individuals appearing on the premises.
9. Distribution of advertising materials using any means in case of additional consent: If you so consent, we may transfer your data to entities of Quirónsalud Group (quironsalud y quironprevencion) in order to inform you—via any means and for promotional and advertising purposes—as to the health- and health-care-related facilities, services, products, or events of the companies belonging to the Quirónsalud Hospital Group (under no circumstances will your data be used to send you advertising content from third parties).
10. Location (Geolocation) of the patient: if you explicitly consent, your location data may be processed to welcome you and offer you specific services aimed at a better experience within the hospital such as interior guidance in the hospital facilities, self-registration of admission if you have a medical appointment, self-registration in emergencies, among others) and / or to provide you with information on the health centers of Quirónsalud Hospital Group and pharmacies closest to your location.

The information collected will be processed for the established purposes, and under no circumstances shall data be processed toward ends that conflict with those established here. Please note that the processing of data for purposes related to scientific research or statistical measurements is not considered to be incompatible with the initial purpose.

We process your data with the same degree of care and quality at all times, regardless of the channel you may choose to communicate with us (e.g. the web page of a facility, mobile apps, face-to-face, telephone, computer).

What are the legal basis for your personal data processing?

How long will we storage your personal information?

In general, your data will be kept only for the length of time strictly necessary for the purpose for which said data were collected.

The personal data provided, as well as data derived from the health care delivered, are kept only for the storage period appropriate to each case (in accordance with medical and legal criteria); these data will be maintained for a minimum of 5 years as of the date of each care episode, with the exception of cases in which regional and/or specific regulations stipulate that this period must be longer than that mentioned above.

After the aforementioned minimum period has elapsed, and once the care and contractual relationship has concluded, the data controller will keep the data for the legally stipulated period (15 years).

The personal data processed for purposes of scientific research shall be maintained, in adherence of retention criteria, for a period not to exceed five years as of the termination of the research. With regard to data processed for purposes of scientific research, the competent regional authorities may, upon request of the data controller and in accordance with established regulatory procedures, order prolonged retention of the entire set of certain data for purposes of historical, statistical, or scientific research in adherence of applicable legislation in each case.

Personal data provided for the purposes of processing information requests, complaints, suggestions, grievances, or the exercising of data-protection rights of any sort, etc., shall be retained for the period necessary to process the request. In all cases the minimum period shall be that which is legally mandated as well as that required to file grievances, exercise rights, or for the defense against such grievances or the exercise of individual rights.

Data processed to comply with legal obligations will be kept for the storage period set forth in applicable legislation.

Data gathered to sign and perform a contract shall be retained for the duration of the contractual relationship as well as the period necessary to file grievances, exercise rights, or for the defense against against such grievances or the exercise of individual rights. This period shall not be less than five years.

Images recorded using video surveillance systems will be retained for a maximum of 30 days, unless the data controller becomes aware of any facts that may be relevant to subsequent legal proceedings.

Personal data processed for the distribution of advertising materials will be retained until the concerned party withdraws his or her consent and/or exercises their right to oppose the retention of such data and/or requests that they be deleted.

The data processed for the location (geolocation) of the patient will be kept until the data subject does not revoke the consent. The data subject can change the configuration of his device to consent or oppose to the collection of the information or the display of the corresponding notifications.

Who will receive my personal information?

In order to guarantee an adequate provision of the service, it is necessary that certain service providers and/or group entities that process data on behalf of the person in charge and as managers of the treatment of your personal data. These entities can be, for example, providers of medical, diagnostic, clinical analysis, auditing, physical security, archiving, storage or digitalization of information, destruction of documentation, legal advisory services, computer services, etc. In some of these cases we inform you that certain medical treatments may entail international data transfers. However, they will always be carried out following the appropriate guarantees established in the data protection regulations (either through standard contractual clauses approved by the European Commission or based on the existence of an adequacy decision by the Commission). If you want more information, or obtain a copy of said guarantees, you can contact the data protection officer.

Your personal data will not be communicated to third parties except legal obligation, vital interest, legitimate interest, or prior consent of the interested party, as well as in the cases and to the recipients that are detailed below:

a) The data of the patients may be visible by other health centers of the Quirónsalud Group, based on the legitimate interest of the data controller, in order to guarantee and/or improve their affiliation, as well as healthcare provision by the Quirónsalud group, in such a way that the health centers can have accurate and updated knowledge of the health data of the patients, thus guaranteeing a comprehensive and effective care provision.

b) Given that the patient may have an insurance contract by virtue of which a third party (for example, insurance companies, mutuals, public administrations, even those of a third party in the case of civil liability insurance) is the party obliged to pay of the health services provided by the health center, as long as the patient makes it known, we may communicate their data to said entities, in order to manage, validate, verify and control the payment of the care services provided on the legitimacy of the management of health care systems and services and Law 50/1980 of the Insurance Contract.

In the event that the patient has an insurance contract with an entity located outside the European Economic Area [1], (hereinafter EEA) whose legislation does not offer a level of data protection equivalent to that of the European Union, it may be necessary to make an international transfer of data, with the explicit consent of the patient after having been informed of the possible risks. We inform you that said transfers only occur with the purpose of collaborating with the patient and facilitating the payment of the care services provided; In short, these transfers only take place, for the most agile possible management and verification with the insurer, of the payment of the services in cases in which the patient has contracted an insurance policy with an entity located outside the E.E.E.

If you object to the communication of your data, these entities may refuse to pay for the assistance services received, corresponding to you the payment thereof, since said entities do not have the possibility of verifying, verifying, validating or controlling the correct billing for part of the health center of each of its care processes.

c) The data processed for scientific research purposes may entail international data transfers, in these cases, you will be informed of this possibility as well as the guarantees so that they can be carried out or, failing that, your consent will be requested.

d) We also inform you that your personal data may be communicated to providers of medical supplies, prostheses and implants due to legal obligation, or ambulances based on the vital interest of the patient.

All the information that is provided to us will be treated confidentially and in strict compliance with the security obligations necessary to prevent access by unauthorized third parties.