Privacy Policy
The Management of the private Clinic Kostas Ch. Christoforou in Larnaca (hereinafter referred to as the “Company”, ‘’Clinic’’, “we”, “us” and “our”) values your privacy and the security of your personal data when collecting and processing information about you. This Policy serves the purpose to inform you about the collection, processing, retention and storage of Personal Data, the ways in which they are used and transmitted, the security measures taken by the Company for their protection, the reasons and the type of personal collected data, your rights as a natural person, i.e., the information required for your information in accordance with the institutional framework.
We hereby assure you through this Privacy and Personal Data Protection Policy (“Policy”) that we fully respect and comply with the EU Regulation 679/2016 (“Regulation”) and the relevant Law 125 / I / 2018 of the Republic of Cyprus.
Useful Definitions
Personal Data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, indicatively by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.
Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.
Processing means any operation or set of operations which is performed on personal data or on sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party means a natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
The Controller
We are the Controller in those cases where we determine the purposes and means of the processing of personal data. In those cases, the Controller is the legal person Clinic Dr Kostas Ch. Christoforou Ltd, address 5 Naupliou str., 7101, Larnaca, Cyprus, tel: +357 24667626, Fax: +357 24642780, email: info@christoforouclinic.com.
Principles we adhere to
At the Clinic, we are committed to and adhering to the following principles of processing personal data in accordance with Article 5 of the Regulation. The personal data are:
- processed lawfully, fairly and in a transparent manner in relation to the data subject (principle of ‘lawfulness, fairness and transparency’);
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (principle of ‘purpose limitation’);
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (principle of ‘data minimisation’);
- accurate and, where necessary, kept up to date; we take every reasonable step to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (principle of ‘accuracy’);
- kept in a form which permits identification of data subjects for no longer than it is necessary or as required by relevant Laws (principle of ‘storage limitation’);
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organisational measures (principle of ‘integrity and confidentiality’).
Finally, we are able to demonstrate compliance with the aforementioned principles (principle of ‘accountability’).
Collection of Personal Data
We as the Controller collect your Personal Data in the following cases:
- When you contact us directly or indirectly (e.g., through our webpage and/or email, or through our collaborators, or through our Social Media accounts, etc.), in order to be informed regarding our services or ask relevant to our services information;
- If you or a person related to you receive our services, when we provide medical services to you or a person you accompany or associate with, if you cooperate with us, or when you are involved in events related to the offer of our services;
- If you fill in any of our documents or you lodge a grievance with us;
- When your personal data is disclosed to us by third parties – partners under contracts or agreements or under your consent or in case of emergency;
- When you are connected to our webpage or our social media accounts or when visiting our infrastructure where a legal CCTV system is operating due to security reasons;
- When you are an employment candidate;
- When you are one of our employees.
In addition, it is noted that we process personal data, which third parties, usually legal persons, disclose to us if we have the role of Processors on their behalf. In such case these Legal Persons hold the responsibility to properly inform you.
Minors’ Personal Data
Kind of Personal Data we may collect about you as the Controller
Data from the following categories of personal information about you may be collected and processed per case in order to serve the purpose of the data collection and in accordance with the relevant legal basis as described in this Policy:
- Contact details with you or of a natural person you may indicate instead of you (name, surname, address, telephone or fax number, email);
- Occupational information (occupation, company, position);
- Identification information such as identification card or passport or ARC number, date and place of birth, date of issue of the passport and expire date or social insurance number / tax number.
- Information of those involved in agreements, such as necessary part from the above-mentioned information, terms and amounts.
- Information for evaluation and / or treatment of the medical condition such as: date of birth or age, pre-existing illness and history, allergies, medication you are taking, habits that affect your health, symptoms, evaluation of critical points and clinical picture, diagnosis, medical protocols, examinations deemed necessary and pre-operative examinations, details of your doctor, details from previous contacts, details regarding treatments and required care, nursing reports, health data for medical services that were not provided by us but were reported to us either by you or by third parties, details of the new-born, contact person in case of emergency, time of hospitalization, nutritional issues and outcome at discharge.
- Authorisations to related persons in relation to the provision of services, or for the transmission of information to third natural or legal persons containing data from the above categories and object of authorisation.
- Your consent regarding medical procedure/operation, type of medical procedure/operation, date, name of doctor, witness, signatures, patient or guardian options, type of delivery, embryo weight, complications / scheduling.
- Under your explicit consent or that of the person accompanying you in case you are not able to give immediate consent, we may photograph elements of medical interest such as rashes, wounds, sores, ulcers and the like, for the purpose of comparative medical evaluation or diagnosis and the progress of your health.
- Payment and transaction details (IBAN, account number, tax number, desired payment method, data of credit/debit card, terms of payment, depositors name etc.);
- Incident investigation data, such as incident details, data of persons involved and related information;
- Client history (satisfaction, transaction details, claims, problems, terms) and information related to assessing persons and situations;
- Apps / websites / social media related data (cookies, IP address, full name or nickname, information you publicly disclose and comments on social media, or email attachments);
- Your picture when under your consent appears in our social media accounts or our website or when you visit our facilities where a recording system (video surveillance) operates for security reasons.
- Employment data and/or data referred within your Curriculum Vitae and data related to studies, competencies or previous working experience if you disclose this information to us as candidates.
It is noted that we collect other kind of personal data about our employees; they are informed through documents, manuals, policies and procedures and information internally provided.
Purposes of Processing & the Legal Bases of Data Processing
The processing of personal data from us as the Controller is based on one of the “legal bases” as referred to in Article 6 of the Regulation (or Article 9 in case of special categories of personal data).
The legal bases on which the collection and processing of personal data is based (in most of the cases) are, the consent, the compliance in performing our contractual obligations, the compliance with our legal and statutory obligations, processing necessary to safeguard the vital interest of yourself or another natural person, and the safeguarding of our legitimate interests. In the case of special categories of personal data, the explicit consent, the performance of obligations and the exercise of specific rights of the controller or data subject in the field of labour law and social security / social protection law and for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment. The legal basis, on which the processing of your personal data is based, is as follows for each processing purpose:
Consent: when you communicate with us in any way directly or indirectly as interested in our services, when you are interested in working to or cooperate with us, when you fill in our documents, when you make a complaint, when you visit our webpage or social media accounts, when you expressly and freely consent to take a photograph, when you give us your business card.
Commitment to perform our contractual obligations: when you have agreed to receive our services, when you are our employee or collaborator, during the payment of our liabilities or when we are contacting you in the framework of a contract.
Compliance with our legal obligations: to comply with our legal obligations to all sorts of authorities such as medical authorities, labour law, regulatory authorities, tax, accounting, auditing, judicial authorities and agencies or in connection with our contractual obligations or during payment of our liabilities.
Safeguarding your vital interests for the purposes of diagnosis, prevention and treatment.
Safeguarding our legitimate interests: to improve our services, or when investigating and managing any potential incident, to receive our payment, or for the assessment of persons and situations. Also, when you are entering our facilities where we operate legally a video surveillance system with the purpose of the security of persons and the property.
Our employees are informed about the processing purposes and the legal bases under specific documents internally.
Retention of Data Period
We store personal data for as long as it is required by the respective processing purpose and any other permitted linked purpose.
Data collected on the basis of contractual and legal obligations shall be retained after the expiry of the contractual and legal obligations as provided by the relevant institutional framework.
Data that may be necessary to safeguard our legitimate interests as the Controller, are kept until the reason for their observance ceases or until the limitation of enforceable rights, as the case may be.
Specifically, for the data we process based on your consent, these are kept from obtaining the consent until it is revoked or there is no longer need to store it.
Cookies are stored depending on their categories as you may be informed in our cookies policy.
Personal data you disclose to us as candidates are stored for 12 months.
The personal data of the CCTV system, is kept for 15 days.
Information that is no longer necessary is safely destroyed or anonymised. We limit access to your personal data to those employees who need to use it for the specific purpose.
How we ensure the security of Personal Data
We have received reasonable organisational and technical measures to protect the personal data we collect and process. We follow international standards and practices to ensure the security of our networks. We ensure you that your personal data is processed securely and legally, by adhering to policies and developing and implementing procedures in accordance with the purposes and legal bases of processing. For example, the following security measures are used to protect personal data against unauthorised use or any other form of unauthorised processing:
- Access to personal data is restricted to a limited number of authorised employees under a need-to-know basis, and the necessary data transfer is done by secure procedures.
- We use pseudonymisation during some processing activities.
- Our employees are bound by confidentiality rules and agreements, with limited classified access to the necessary data only.
- We select trusted collaborators who are bound in writing, in accordance with Article 28 of the Regulation, with the same obligations regarding the protection of personal data. We reserve the right to audit them in accordance with Article 28 (3) (h).
- In our ICT systems used for the processing of personal data, all technical measures are taken to prevent loss, unauthorised access or other illegal processing.
In addition, access to these ICT systems is monitored on a permanent basis in order to detect and prevent illegal use at an early stage. Although the transfer of data through the Internet or a web site cannot be guaranteed to be protected from cyberattacks, we work to maintain physical, electronic and procedural security measures to protect your data.
Some of the security measures we take are not announced for obvious reasons.
To whom the Data may be disclosed
We take measures to ensure that the recipients of personal data we process as the Controller are kept to a minimum. The personal data we process as Controller are disclosed to third parties, provided that the legality of such disclosure is fully justified. Specific personal data from those we lawfully process as the Controller, may be accessed by (or disclosed to) on a case-by-case basis by:
- Any relating supervisory authority within its role;
- Any public or judicial authority where required by law or judicial decision.
- The external IT Administrator under specific clauses of confidentiality.
- The auditor of the company, and only in relation to necessary financial data.
- The advocate, for whatever data is required in legal cases, under confidentiality.
- Upon your direct or indirect order, your personal data may be disclosed to third parties (for example another doctor of your choice) or to cooperating insurance companies and only for the required part of information.
- Partner banks (of the company, the staff or affiliates and suppliers), only for payment related data.
- The training or systems consultants, the trainer and HRDA (Authority for the human resource training) for training or systems control issues and only for the necessary parts of information and data.
The above third parties, except the Authorities, have contractually agreed with the Company, that they will use the personal data only for the specific per third party purposes, will not transmit the personal information to other third parties, and that they will not disclose it to third parties unless required by law or court decision.
Territorial Scope
Your rights as a Data Subject and how you can exercise them
You have the right to be informed, the right of consent if it is the legal basis for the processing, the right of access to your personal data, the rights of rectification and erasure (in cases it is permitted), the right to restriction of processing, the right to data portability, the right to object. If processing is based on your consent, you may withdraw it at any time.
The right to be informed is exercised through this privacy and personal data protection notification. In some cases, it is also mentioned on documents and forms we are using. You may ask a hard copy of our policy by communicating with us.
Your right to be informed regarding the video surveillance system (CCTV) that operates legally by recording for the security of people and the property, is exercised with the existence of appropriate information signs before you enter the recording range. Additional information (level 2 information) can be requested at the reception of the Clinic.
The right of consent is provided by design as we have reviewed all processing activities and ask your consent when the case.
We inform you that we as the Controller are not using software of decision making solely based on automated processing including profiling. More specifically, you have the following additional rights, provided that you will exercise them in writing and after the verification that you are the data subject.
Right of access: you have the right to obtain from us confirmation as to whether or not your personal data are being processed as well as other relevant information, and, where that is the case, access to your personal data.
Right of rectification: you have the right of rectification of your inaccurate personal data as well as to have incomplete personal data completed by providing a supplementary statement.
Note: Since it is not possible for us to be aware of any changes to your personal data if you do not inform us, please help us keep your information accurate by informing us of any changes to your personal information we do process.
Right to erasure (‘right to be forgotten’); we have to answer such right when:
- your personal data are no longer necessary in relation to the purposes for which we collected it;
- withdraw your consent on which the processing is based and where there is no other legal basis for the processing;
- your personal data have been unlawfully processed;
- personal data have to be erased for compliance with a legal obligation we are subject to;
- personal data have been collected in relation to the offer of information society services.
We reserve the right to refuse this right if the processing is necessary for compliance with any legal obligation, we are subject to, or for reasons of public interest, or for the foundation and exercise or support of our legal claims (according Article 17 § 3).
Right to restriction of processing; you have the right to restriction of processing when:
- you contest the accuracy of your personal data for a period enabling us to verify the accuracy of the personal data;
- the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
- we no longer need your personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
- you objected to processing pending the verification whether our legitimate grounds override those of yours.
Right to data portability: You have the right to receive your data in a structured, commonly used and machine-readable format and under an explicit request such data to be transferred to both you and another natural or legal person who will process it.
Right to object: you have the right to object to the processing of your data at any time when the reason for the processing relates to direct marketing.
All the above describe your rights where we are the Controller. In cases we are the Processor then your rights related requests should be addressed to the Controller.
In the event that you make such request in a written or electronic form regarding any of the above rights, we will assess your request and respond within one month of its receipt, either for its satisfaction or to provide you with objective reasons preventing it from being satisfied, or, given the complexity of the request and the number of requests at the given time, request an extension of response for a further two months period (according Article 12.3 of the Regulation).
The exercise of your rights is free of charge. Where requests from you are manifestly unfounded or excessive, in particular because of their repetitive character, we may refuse to answer or charge you an administrative fee.
If you are dissatisfied with the use of your data by us, or our response after exercising your rights, you have the right to lodge a complaint with a supervisory authority.
Personal Data Breach
In the event of a breach of the security of the personal data processed, we will take the following measures (in accordance with Article 33 and 34 of the Regulation in case we are the Controller) and we will:
- Assess it in order to implement the appropriate procedures needed to limit the breach;
- Examine the extent of the breach and the sensitivity of the data included;
- Evaluate the risk and its impact on your rights and freedoms;
- Endeavour to reduce as much as possible the damage that is or may be caused;
- Notify within a time limit of 72 hours of becoming aware of the breach, the National Personal Data Protection Authority, if required;
- Assess the impact on your privacy and take appropriate measures to prevent the repeating of the incident.
In the event we are the Processor, we will inform the Controller as soon as possible.
