Privacy Policy

MAGNETIC RESONANCE IMAGING CENTER: MRINNI

Patient Privacy Notice, v1, April 2022

Key leements:

  1. Why do we use your data? We use information about you for the purpose of providing you with our MRI diagnostic services. We use your sensitive data: As a patient, we will use information about your health, age, gender, weight and height.
  2. Sharing data: We may share your data with third parties, including other healthcare providers who may contribute to your diagnostic procedure, statutory bodies concerned with the regulation of your care, and other medical institutions who may be involved in your healthcare.
  3. Security: We respect the security of your data and treat it in accordance with the law. International transfer: We may transfer data with the patient’s express consent.

Neurology and Neurosurgery Institute ”Diomid Gherman” respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after patient’s personal data and tell you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

  • Under the requirements of national law nr. 133 / 2011 and UE General Data Protection Regulation , we are required to explain to our patients why we collect information about you, how we intend to use that information and whether we will share this information with anyone else.
  • This statement applies to all our patients and also prospective patients.
  • We may update this statement at any time, and we will provide you with a new privacy statement when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
  • It is important that you read this statement so that you know how and why we use information about you. It is also important that you inform us of any changes to your personal information so that the information which we hold about you is accurate and up to date.
  • We are Neurology and Neurosurgery Institute ”Diomid Gherman” a public HealthCare institution and are a “data controller” for the information which we hold about you. This means that we are responsible for deciding how we hold and use the personal information which we hold about you.
  • We have empowered a Data Protection Office (“DPO”), and we make all arrangements to involve our security unit and independent specialists to be responsible for overseeing what we do with your information and monitoring our compliance with data protection laws.
CONTACT DETAILS
  • Our full details are:

Full name of legal entity: registered in Republic of Moldova under the company number 1003600150602 and whose registered address
DPO email address: dpo@innirm.md
Postal address: MD 2028, mun. Chișinău, str. Korolenko, 2
Telephone number: +373 22 82 90 27

You have the right to make a complaint at any time to the Centrul Național Pentru Protecția Datelor cu Caracter Personal, the R. Moldova supervisory authority for data protection issues ( www.datepersonale.md ). We would, however, appreciate the chance to deal with your concerns before you approach the CNPDCP so please contact us in the first instance.

2. WHY ARE WE COLLECTING YOUR INFORMATION?

  • We ask for information about you so that we can make sure we can provide you MRI diagnostic service as our patient and be aware of your specific needs.
  • Where we need to collect personal data either by law or healthcare regulators, or under the terms and conditions and you fail to provide that data when requested, we may not be able to provide you with the service you require, but we will notify you if this is the case at the time.

3. TYPES OF PERSONAL INFORMATION WE USE

3.1. We are collecting information about you which is relevant to your medical investigation(s) which we provide to you. This includes:

  1. personal details (such as name and surname, IDNP or passport number, date of birth, gender, national insurance number);
  2. contact details (such as your address, personal telephone numbers and personal email address);
  3. contact information about your next of kin (for the purpose of emergency contact details);
  4. information about other healthcare providers (such as your GP and practice details, referral doctor contact information);
  5. video of you (such as CCTV footage for security purposes).

3.2. SPECIAL CATEGORIES OF PERSONAL DATA

Some of the information which we collect about you may be “special categories of personal data”. Special categories of data require a greater level of protection. The special categories of personal data about you which we may collect include:

  1. healthcare information, including:
  • any disabilities or special requirements which you may have;
  • preliminary diagnostic set-out by GP or referral doctor;
  • medical records relating to your treatment by us;
  • and records required by care regulators.

AGGREGATED DATA
We also collect and use anonymised and aggregated data (“Aggregated Data”) such as statistical data for our own internal purposes. Aggregated Data is be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

4. SOURCE OF YOUR PERSONAL INFORMATION

  1. The above information which we collect about you will be obtained through a variety of sources which include:
  • from you directly both prior to and during the course of your servicing by us;
  • from your next of kin who provide us with information about you;
  • from national healthcare informational systems, professionals and officers in the local authority.

5. HOW AND WHY WE USE YOUR PERSONAL DATA

  1. In accordance with the data protection laws, we need a “lawful basis” for collecting and using information about you for any particular purpose.
  2. We have set out below the different purposes for which we collect and use your personal data, along with the lawful bases on which we will rely.

Why we use your information

Our lawful basis for using your information

Provision of MRI diagnostic services:
To provide you with safe, appropriate and in accordance with your personalised need care as one of our patients and ensure that we meet your individual requirements.

It is necessary to perform our services to you.
It is necessary to meet legal/regulatory obligations.
It is necessary for our legitimate interests (where they are not overridden by your rights).
It is necessary for the protection of your vital interests.

Finance:
Administering payments for your MRI diagnostic by us.

It is necessary for our legitimate interests (where they are not overridden by your rights).
It is necessary to meet legal/regulatory obligations.
It is necessary to perform our services to you.

Admin:
Administrative matters which are necessary for the day to day functioning of our MRI Cener. This may occasionally include the prevention, detection and investigation of fraud and corruption.

It is necessary to perform our services to you.
It is necessary to meet legal/regulatory obligations.
It is necessary for our legitimate interests (where they are not overridden by your rights).

Complaints:
Handling any complaints made, concerns raised.

It is necessary to meet legal/regulatory obligations.
It is necessary for our legitimate interests (where they are not overridden by your rights).
It is necessary for the protection of your vital interests.

Safeguarding and regulation:
We use your personal data for the purpose of safeguarding and regulation of healthcare.

It is necessary to perform our services to you.
It is necessary to meet legal/regulatory obligations.
It is necessary for our legitimate interests (where they are not overridden by your rights).
It is necessary for the protection of your vital interests.

Communication:
We will need to use your personal information to communicate with you before, during and after your appointment.

It is necessary to perform our services to you.
It is necessary for our legitimate interests (where they are not overridden by your rights).

Security:
We may need to capture images of you as part of our security processes such as use of CCTV footage.

It is necessary for our legitimate interests (where they are not overridden by your rights).
It is necessary for the management of your safety during appointment and investigation.

6. COMPLYING WITH DATA PROTECTION LAW

  1. We will comply with data protection law when using your personal information. At the heart of data protection laws are the “data protection principles” which say that the personal information we hold about you must be:
  • used lawfully, fairly and in a transparent way;
  • collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
  • relevant to the purposes we have told you about and limited only to those purposes;
  • accurate and kept up to date;
  • kept only as long as necessary for the purposes we have told you about;
  • kept securely.

7. SHARING YOUR INFORMATION

  1. We will share your personal information with third parties where we have a lawful basis for doing so.
  2. The types of organizations with whom we share your personal data are as follows:
  • Healthcare providers and multi-disciplinary teams: Where it is lawful and necessary to do so, we will share information about you with other medical service providers involved directly with your care including hospitals or specialists to whom you have requested a referral.
  • Regulators/Safeguarding authorities: We also share your personal data with these public bodies where we are required to do so by law.
  • The Police and other law enforcement agencies: In limited circumstances we may be required to share your personal data with the police if required for the purposes of criminal investigations and law enforcement.
  • IT service providers: We may use external IT providers who may have access to your personal data from time to time as is necessary to perform their services.
  • Attorneys: Where it is lawful to do so, we may share your personal information with any individual who has authority to act on your behalf such as those granted power of attorney.
  • Next of kin: We may share your personal information with your next of kin (if we are aware of their contact details) in an emergency.

8. TRANSFERRING INFORMATION OUTSIDE THE Republic of Moldova

  1. For patients who are not referred to us by a medical doctor or heal care organization outside R.Moldova, we will not transfer data outside of the R.Moldova.

Please contact us at dpo@innirm.md If you want further information on the specific mechanism used by us when transferring your personal data out of the R.Moldova.

9. CAN WE USE YOUR INFORMATION FOR ANY OTHER PURPOSE?

  1. We typically will only use your personal information for the purposes for which we collect it. It is possible that we will use your information for other purposes as long as those other purposes are compatible with those set out in this policy. If we intend to do so, we will provide you with information relating to that other purpose before using it for the new purpose.
  2. We may also use your personal information for other purposes where such use is required or permitted by law.

10. STORING YOUR INFORMATION AND DELETING IT

  1. We will only retain your personal information for as long as necessary to fulfill the purposes for which we have collected it or to fulfill another lawful purpose (as described above). When we no longer have a lawful purpose for holding your data, we will securely destroy your personal information in accordance with our data retention policy. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us at dpo@innirm.md.
  2. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

11. YOUR RIGHTS

1. Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information in certain circumstances. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) or public interest as our lawful basis for processing and there is something about your particular situation which leads you to object to processing on this ground. You also have the right to object if we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
    Request the transfer of your personal information to another party in certain circumstances.

2. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Data Protection Office in writing.

12. RIGHT TO WITHDRAW CONSENT

  1. In the limited circumstances where we are relying on your consent as our lawful basis to process your data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Office. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

13. AUTOMATED DECISION MAKING

  1. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

14. RIGHT TO COMPLAIN TO THE CNPDCP

You have the right to complain to the Centrul Național Pentru Protecția Datelor cu Caracter Personal if you are not satisfied with the way we use your information. You can contact Centrul Național Pentru Protecția Datelor cu Caracter Personal Republic of Moldova, MD-2004, Chisinau, 48, Serghei Lazo Str.