We process your personal data in order to provide you with the best possible service. We believe it is important that your privacy is in good hands with us. That is why we handle your personal data carefully and we have taken appropriate technical and organizational measures to protect your data. We adhere to the applicable rules for the protection of personal data, including the Algemene Verordening Gegevensbescherming (AVG) (General Data Protection Regulation). This privacy statement applies to Elquirin, Therapy and Training, the practice of drs. Ellen M. de Jong and drs. Louis H.M. Crijns.
Which personal data do we process?
We receive most of the personal data that we process from you.
- Your contact details such as your name, address, place of residence, telephone number and e-mail address.
- Your date of birth
- Healthcare providers may use the BSN (citizen service number), for example, if they work under the Zorgverzekeringswet en de Wet langdurige zorg (Health Insurance Act and the Long-Term Care Act). This is not the case with a complementary or alternative therapist. The declaration in the context of the additional health insurance does not fall under the Zorgverzekeringswet (Health Insurance Act) and is not a ground for using the BSN. ElQuirin is therefore not allowed to record the BSN.
Why do we process your personal data?
In addition to the AVG, the WGBO (Wet op de geneeskundige behandelingsovereenkomst, Medical Treatment Contracts Act) and the professional code of our professional association and of the Register Beroepsbeoefenaren Complementaire Zorg (RBCZ: Register Professional Practitioners Complementary Care) apply to our work. These affect the purposes for which we record personal data. For that reason, we handle personal data as follows:
- File obligation
On the basis of the Wet op de geneeskundige behandelingsovereenkomst (WGBO), we as a healthcare provider are obliged to keep a medical file. We work with paper files.
- Retention period
The main rule for the storage of medical files is contained in the WGBO. That is 20 years, calculated from the time when the last change in the file took place. The term can be longer if this is necessary in view of the treatment (for example if someone has a chronic illness).
- Professional confidentiality
For us as a therapist, a confidentiality obligation applies on the basis of the professional code and the statutory medical confidentiality. Employees of a psychosocial or complementary practice are bound by a duty of confidentiality through an employment contract.
According to the patients’ rights under the WGBO, the competent minor between 12-16 years old and the parent (s) have custody. Parent (s) of minors up to the age of 16 have co-decision about the treatment. Parents have the right to information and access to the file, when this is linked to the right of co-decision for the treatment. There is an exception to this right of access, namely when the professional is of the opinion that the exercise of certain patients’ rights is contrary to the patient’s interests. Competent patients aged 12 and older are themselves authorized to give permission for a breach of confidentiality.
Who do we share your personal data with?
We do not share personal data with health insurance companies. You are responsible for submitting the invoice for declaration.
Suppliers with whom we have concluded a processor agreement are the company that maintains our server. Our tax advisor only receives anonymous data.
What do we do in case of data leakage?
Since 1 January 2016, the data breach notification requirement has applied. This duty to report means that organizations (including therapists) must immediately (within 72 hours after the data breach) report to the Dutch Data Protection Authority as soon as they have a serious data breach.
Sometimes they also have to report the data breach to the data subjects (the people whose personal data has been leaked).
What rights do you have?
You are of course in charge of your own personal data. That is why the Algemene Verordening Gegevensbescherming (AVG) gives you a number of rights. You may ask us to:
- access to the personal data that we process about you.
- information about what we do with your personal data.
- have your personal data corrected if they are incorrect.
- delete your personal data.
- restrict or even stop the processing of your personal data.
- we always try to comply with your request as soon as possible, but no later than one month after submission. We do not charge any costs for this. Please note that we cannot always meet your request. For example, a request to delete your personal data while the legal retention period has not yet expired or if you still have a contract through us. If we cannot comply with your request, we will of course let you know.
Adjustment of this privacy statement
We may adjust this privacy statement. It is therefore wise to check this statement just before providing your personal data to us.
Do you have questions?
If you have any questions or would like to exercise your rights under the Algemene Verordening Persoonsgegevens (AVG), please contact your Elquirin therapist / contact person.
The Hague, revised version 7/10/2020