Privacy Statement Andromeda Center for Osteopathy

This is the Privacy Statement of Andromeda Center for Osteopathy. To provide you with quality care, Andromeda Center for Osteopathy processes your personal data. In this document, we explain how we handle your information.

Andromeda Center for Osteopathy considers the careful handling of your personal data to be of great importance. Your personal data is therefore processed and secured with care.

Why Does Andromeda Center for Osteopathy Have a Privacy Statement?
In this Privacy Statement, we outline how we handle your personal data. You can read which personal data we process, for what purposes, who may access your data, how we store your data, to whom we may share your data, and what control you have over this. Your privacy is our priority!

What Are Personal Data?
Personal data are all data that can be traced back to an individual—meaning you. Examples of personal data include your name, address, date of birth, phone number, email address, health insurance number, and citizen service number (BSN). We obtain such data from you when you fill out a form, send a letter or email, or contact us by phone. Additionally, when you visit the Andromeda Center for Osteopathy website, certain data, such as an anonymized IP address, may be collected.

When your personal data is shared with Andromeda Center for Osteopathy—either by yourself or a third party—we process this data. Processing includes collecting, storing, consulting, deleting, using, and sharing data with others beyond Andromeda Center for Osteopathy.

What Does This Privacy Statement Apply To?
This Privacy Statement applies to all personal data that Andromeda Center for Osteopathy processes (either fully or partially automated) in the course of its services.

Whose Personal Data Does Andromeda Center for Osteopathy Process?
We may process personal data of all individuals we interact with or who visit the website of Andromeda Center for Osteopathy. These include patients, employees, business clients, suppliers, and business partners.

Important: If you, as an organization or business, share personal data of your employees with us, you are legally required to inform your employees. You may provide them with this Privacy Statement so they understand how Andromeda Center for Osteopathy handles their personal data.

Who Is Responsible for Processing Your Personal Data?
The responsible party for processing your personal data is Andromeda Center for Osteopathy, located at Andromeda 4, Veldhoven.

Andromeda Center for Osteopathy formally and legally determines whether and which personal data are processed, for what purpose, and how.

Why Does Andromeda Center for Osteopathy Use Your Personal Data?
Andromeda Center for Osteopathy processes your personal data based on legal grounds, including:

• Your consent;
• Necessity for the execution of an agreement;
• Compliance with legal obligations;

and

• Protection of serious risks to your health.

We process your personal data for quality care and efficient operations, specifically for:

Providing Quality Care

Registration and Intake

We collect your name, address, contact details, and referral information to ensure safe and appropriate care. We verify your identity but do not make copies—only noting document type and number. We also collect medical history, lifestyle habits, and other relevant health details to make an accurate osteopathic diagnosis.

We then ask you for various information regarding your complaints, medication use, profession, lifestyle (smoking, alcohol and drug use), previous treatments, your activities, etc. This is called the anamnesis and is part of your intake. We do this to arrive at a correct osteopathic diagnosis and to make a proper assessment of the best treatment (with us or elsewhere), the risks, and expectations.

All healthcare providers within Andromeda Center for Osteopathy who are directly involved in your treatment have access to this data.

The electronic patient record (EPR)
Andromeda Center for Osteopathy uses the Intramed electronic patient record (EPR).

An EPR is a software application in which your personal and special data are stored and made available in digital form. The purpose of an EPR is to support the current care process surrounding you. In addition, it supports Andromeda Center for Osteopathy in work processes, planning, communication, file formation, and finances. The data is available to your practitioners at Andromeda Center for Osteopathy and supporting staff, such as administration/planning staff, financial administration, and the quality manager. Supporting staff have signed the Andromeda Center for Osteopathy privacy regulations, which include a statement on the duty of confidentiality regarding personal data. Andromeda Center for Osteopathy has entered into a processing agreement with Intramed, which safeguards your privacy.

Complaints and disputes
When submitting a complaint to the complaints officer, you are asked to describe your complaint as clearly as possible. You are also asked to provide your name, address, and contact details so that the complaints officer can contact you.

The complaints officer is bound by confidentiality and safeguards your privacy. Your complaint will be treated confidentially, with the complaints officer maintaining an impartial position. Complaints are registered and reported annually. This is done without mentioning your personal details. For the handling of complaints or disputes, it may be necessary for the Andromeda Center for Osteopathy complaints officer or the disputes committee to receive a copy of your file containing relevant information. For this, the complaints officer or the external disputes committee will first request your specific, written consent. In this regard, we refer to the Osteopathy complaints procedure brochure, which can be found in the waiting room.

Incidents, calamities, and special situations
For systematic monitoring, control, and improvement of the quality of care, it is important to report and analyze unintended events during the care process that have led or could lead to harm to the patient (‘incidents’). This is also referred to as the VIM system (Safe Incident Reporting).

With your consent, we may make patient data available that is necessary to investigate the incident. The data in the reporting system is not public, not even for the patient. The data can only be used by the persons handling the incident. The findings report is for internal use; the patient does not receive a copy and has no right to inspect this report. You will, however, be informed about the incident and the report thereof.

We are obliged to report serious calamities to the Health and Youth Care Inspectorate; we do not request permission for this. In the event of a possible outbreak of infectious diseases, we are obliged to pass on your details to the GGD (Municipal Health Service).

In case of suspected domestic violence or child abuse, we are also obliged to report this.

Marketing and communication

On our Andromeda Center for Osteopathy website, we only use functional cookies from Google Analytics, with whom we have a processing agreement. No information is shared with Google. When you visit our website, we register your IP address, visit data, and cookies. General visit data is kept on the Andromeda Center for Osteopathy websites, such as the most visited pages. With this information, we can further optimize the layout of our website.

Supervision of the processing of personal data
The rules regarding the protection of your personal data are laid down in the Personal Data Protection Act; as of May 25, 2018, this concerns the General Data Protection Regulation (GDPR). The Dutch Data Protection Authority (AP) ensures compliance with this law.

If you believe that the provisions of this Privacy Statement are not being complied with, or are being insufficiently complied with by us, you have the right to submit a complaint to the AP.

The contact details for the AP are:

Bezuidenhoutseweg 30
2594 AV The Hague Tel. no. 0900-2001201

Secure
To protect your privacy and the confidentiality of your data, Andromeda Center for Osteopathy takes appropriate technical and organizational measures. The Intramed electronic patient record complies with information security standards. The virtual workstations in the computers of Andromeda Center for Osteopathy are only accessible with a personal password. This password is only known to the employee themselves. The password changes periodically, every 3-4 months. Agreements have been made with all employees of Andromeda Center for Osteopathy regarding locking or hiding the information on the screen as soon as the computer is left unattended.

We take security measures to prevent misuse of and unauthorized access to personal data.

In addition to securing the systems, we also want to ensure that not everyone within Andromeda Center for Osteopathy has access to your data. Parts of systems in which client data is stored are therefore only accessible to a select group of employees for whom access is necessary to perform their duties.

Our electronic healthcare systems, which contain your medical data, are secured in various ways, including access restrictions, logging, etc. We also take measures against data loss, such as backups, and against fire, loss, or theft.

Other measures we take include:

• We have drawn up a code of conduct for employees and hired third parties.
• Employees possess sufficient knowledge in preventing security incidents and using the data breach reporting protocol in the event that your data is misused despite all measures.
• Where possible, use is made of exchange systems and encrypted email traffic.

Reporting incidents
Should it unexpectedly turn out that something has gone wrong with the protection of your personal data, or if we suspect this to be the case, we will report this to the AP. If the breach of your personal data could have unfavorable or detrimental consequences for you, we will let you know as soon as possible.

Confidential
We assume that your data is always confidential in nature. Every employee of Andromeda Center for Osteopathy is therefore bound by confidentiality. This also applies to third parties hired or otherwise appointed by Andromeda Center for Osteopathy to perform work. Persons charged with performing technical work on our systems are also bound by confidentiality.

How long do we keep your data?
Andromeda Center for Osteopathy does not store your data longer than is necessary for the purposes for which your data is processed and than is legally permitted. How long certain data is kept depends on the nature of the data and the purposes for which it is processed.

Provision to third parties
We explicitly do not provide your personal data to third parties, unless this is necessary in the context of the execution of the treatment agreement, if this is legally required, or when you have given us your consent for this.

If we exchange personal data in the context of your treatment agreement, this will usually be with:

• Healthcare providers or social domain professionals who support you or will support you.
• Family or informal caregivers
• Medical equipment suppliers

Your practitioner will explain to you why and with whom they wish to exchange personal data.

Andromeda Center for Osteopathy may also be obliged to provide personal data based on laws or regulations, based on a ruling by a competent court, or in the event of fraud or misuse. If that is the case, Andromeda Center for Osteopathy will provide its cooperation.

Transfer of your data to countries outside the European Union
Andromeda Center for Osteopathy will not transfer your data to a company or branch in a country outside the European Union.

Personal contact with Andromeda Center for Osteopathy

Many contacts between you and Andromeda Center for Osteopathy take place by telephone, via forms, or by email. We record personal data that you provide in the process if this is necessary for our services.

What are your rights?
When Andromeda Center for Osteopathy processes your personal data, you have certain rights according to the applicable regulations. Your rights will be explained below.

Access to your data
Are you a client of Andromeda Center for Osteopathy and would you like to see which of your personal data is known to us? Then you can make use of your ‘Right of access’. We request that you specify which personal data you would like to receive. You can request the procedure for this from our complaints officer.

Right to rectification
You have the right to rectify data if your data is incorrect or incomplete. You also have the right to rectify the data if the data is not relevant for the purpose for which we process it, or if your data is in violation of a legal requirement.

We will inform the third party/parties who have received your data from us of any rectification, unless this is impossible or requires a disproportionate effort from us.

Right to erasure
In addition, you have the right to have certain data deleted. For example, when your data is no longer necessary for the purposes for which we received it, you object to the processing, or when your data has been processed unlawfully by us. However, we cannot always delete all requested data, because we (may) be obliged to keep certain data of yours.

Right to restriction of processing
You also have the right to restriction of the processing of your data. The right to restriction means that we may (temporarily) not process and not change your personal data. This applies if you dispute the accuracy of the data, if you believe that the personal data is no longer necessary for the purposes, or if you believe that the processing of your personal data by Andromeda Center for Osteopathy is unlawful.

Right to object
You can object to the processing of your personal data by Andromeda Center for Osteopathy if your personal data is used for purposes other than those necessary for the execution of an agreement or necessary for compliance with a legal obligation.

Right to data portability
When you have provided your personal data to us yourself, you have the right to data portability in certain cases. This means that we will provide your data to you in a structured, commonly used, and machine-readable format, when you request us to do so.

How can you exercise your rights?
If you wish to exercise your rights, you can contact us at any time via our complaints officer. We will respond to your request within one month.

We ask you to identify yourself with a valid ID. In this way, we can check whether we are providing the personal data to the correct person.

Excessive requests regarding the provision of information may be refused by us. Excessive requests occur when, for example, you approach us with information requests more than average.

About this privacy statement
Andromeda Center for Osteopathy may adjust this Privacy Statement. The last change was on January 1, 2019. The most recent version can always be found at www.andromeda-osteopathie.nl.

Do you have questions or comments about our Privacy Statement? Please feel free to contact us:

Andromeda Center for Osteopathy
Andromeda 4
5505 RM Veldhoven
Tel. no. 040-2541154 (extension 1)
info@Andromeda-Osteopathie.nl