1. INRODUCTION
The Fertility Centre AKESO (hereinafter referred to as the “FCA”) is licensed to operate in accordance with the Private Hospitals Law of Cyprus (L. 90(I)/2001) and in accordance with the Cyprus law on setting standards for the quality and safety (for the donation, procurement, testing, processing, preservation, storage and distribution) of human tissues and cells of 2007, as amended (L. 187(I) 2007). For more information in relation to the FCA’s services, visit our website at akeso.com.cy.
The protection of personal data for all patients and our associates is of the outmost importance for the FCA. We take all necessary measures to ensure that all personal data remain protected, in accordance with the applicable national legislation and the General Data Protection Regulation (Regulation (EU) 2016/679) (referred to as “GDPR”).
2. PERSONAL DATA COLLECTION AND PROCESSING
The FCA collects, processes and keeps personal data for the purposes of the services it provides. Any personal data that you provide to us, such as name and surname, date of birth, sex, contact details (residential address, e-mail address, landline/mobile number), occupation, biological samples and medical history, are collected and processed within the framework of our activities.
Your personal data may be collected by you personally or by third parties on your behalf (e.g. clinician).
Legal grounds for lawful processing of your personal data constitute:
- The provision of services that you have requested.
- Compliance with a legal obligation
- Protection of your vital interests and/or our own vital interests.
- Any consent you may give subject to specific conditions set by the legal framework, in order to receive information on the services provided by the FCA.
- Processing that it is necessary for enabling the provision of services by the FCA. In the event that the processing of data is required for different reasons, your written consent will be requested, as in the case of participation of a patient in a clinical study.
- In exceptional cases, your personal data may be used for the establishment, exercise or defense of a legal claim in cases involving medical liability and the provision of health services in general. In such occasions, the data subject(s) will be informed, at the latest, prior to the use of their data before the court.
3. TRANSMISSION OF PERSONAL DATA
The FCA may transmit your personal data to a third party, appointed by the FCA for the processing of personal data on our behalf. In these cases, the FCA remains liable for the handling of your personal data and defines the individual elements of the processing; a special purpose agreement with the aforementioned third party is concluded, in order to ensure that the processing is performed in accordance with the current legislation and that any natural person may freely and unimpeded exercise their rights.
4. ACCESS TO PERSONAL DATA
Only the staff members of the FCA may have access to the patients’ personal data. Each member of the FCA’s staff is required to sign the Code of Conduct and shall receive specialized training regarding the collection, processing and storing of personal data. It is provided that the declaration of confidentiality requires unconditional compliance to the policy of data protection, both during the period of employment and after its termination. The same policy applies for every contracting associate during and after the termination of our business relationship.
Access to personal data is exceptionally permitted:
- To the judicial and prosecutorial authorities in the performance of their duties;
- To other competent authorities on the basis of their statutory provisions, that have a right and duty to access such data.
5. DURATION OF THE RETENTION
The period for the storage and retention of personal data, is determined by taking into account the following criteria, depending on each case:
- If the processing of data is performed pursuant to a contractal arrangement, the personal data is stored for as long as is deemed necessary for the legal performance of the contract and for the establishment, exercise and /or defence of any legal claims in accordance with the contract.
- If the processing is required pursuant to the provisions of the applicable legal framework, your personal data will be stored for as long as the relevant provisions require. In particular, and in accordance with a directive issued by the Data Protection Commissioner, the retention period for medically-related data of the data subject, should not exceed fifteen (15) years following the individual’s death, or fifteen (15) years after the latest data entry by the person responsible. The aforementioned time interval is applicable, when there no other legal or otherwise outstanding issues or disputes between the data subject and the processor.
Medically-related personal data may be stored for a longer duration in a separate filing system, only in the following circumstances:
- The data will be processed solely for scientific and statistical purposes
- The appropriate technical and organisational measures are applied to ensure data minimisation and
- The appropriate technical and organisational measures are applied to prohibit the identification of the data subject
- For the purposes of providing our services and in any other case where the processing is based on your consent, your personal data will be retained until your consent is withdrawn/revoked. Withdrawing your consent may be done at any time. The withdrawal of your consent shall not affect the legality of the processing of your personal data that occurred on the basis of your consent in the period prior to such withdrawal.
To withdraw your consent, please contact the Data Protection Officer: E-mail: info@akeso.com.cy, tel.: 22766222.
6. YOUR LEGAL RIGHTS REGARDING YOUR PERSONAL DATA
Any natural person whose personal data is being processed by the FCA, has the following rights:
Right to access:
You have the right to be aware of the collection and retention of your personal data and have access to it.
Right to correct:
You have the right to study, correct, update or amend your personal data, by contacting the Data Protection Officer of FCA.
Right to erase:
You have the right to submit a request for deletion of your personal data that we retained in our records. This right is subject to specific restrictions or is not applicable, depending on each case.
Right to restrict the processing of data:
You have the right to request the restriction of data processing in the following cases:
- When you contests the accuracy of your data and until verified
- When you request restriction of use of your personal data
- When your personal data is no longer required for the provision of services, but is necessary for the establishment , exercise and defence of legal claims and
- When you contest the processing of your data and until it is verified that there are legal reasons , which prevail over the reasoning behind you objection to the processing of your personal data.
Right to oppose the processing of your data:
You have the right to object at any time to the processing of your personal data in cases where, as described above, it is necessary for the purposes of the legitimate interests we pursue as processors, as well as for the processing for the purposes of direct marketing.
Right to data portability
You have the right to receive your personal data free of charge in a format permitting you to access, use and process it using common processing methods. You also have the right to request that, if technically possible, to transmit/transfer your data directly to another controller.
7. SECURITY OF PERSONAL DATA
The Center takes appropriate technical and organizational measures for the secured processing of personal data and the prevention of accidental loss or destruction and unauthorized and / or illegal access to data, for the use, the modification or the disclosure. In addition, the FCA’s laboratory is ISO accredited 15189(Medical Laboratories- Requirements for Quality and Competence) and it operates in accordance with the Registration and Operation of the Clinical Laboratory Law of 1988 (L. 132/1988). The above-mentioned imply that the FCA takes all necessary measures to ensure the requirements of technical competence while ensuring the confidentiality of information and personal data of customers.. In any case, the fact that internet access is free for anyone, does not allow us to provide guarantee that an unauthorized third party will never be able to violate the technical and organisational measures, by accessing and potentially using personal data for unauthorized and/or unlawful purposes.
8. TRANSFERRING TO THIRD COUNTRIES AND/OR INTERNATIONAL ORGANISATIONS
The FCA will not transmit your personal data to third countries and/or to any international organisations.
9. CONTACTING INFORMATION
For any comments or complaints regarding the processing of your personal data, you may contact the Data Protection Officer (DPO) , at the following address: Pinelopis Delta 11, 1076 Nicosia or the email: info@akeso.com.cy or the telephone number: 22766222, 25824488.
10. RIGHT TO COMPLAIN
You have the right to submit a complaint to the Office of the Commissioner for Personal Data Protection: telephone: +357 22818456, Fax: +357 22304565, E-mail: commissioner@dataprotection.gov.cy