PATIENT PERSONAL DATA PROTECTION
PROCEDURE ACCORDING TO THE LAW ON THE
PROTECTION OF PERSONAL DATA
Doc. Code: HE.PR.02
Publication Date: 06.12.2023
Rev. No/Date: 00
1 - PURPOSE: To ensure the protection of patients' personal data and special categories of
personal data during the provision of healthcare services.
2 - SCOPE: This procedure covers all patients who apply to our hospital or receive treatment in the
hospital.
3 - ABBREVIATIONS:
4 - DEFINITIONS:
4.1 Data Subject: The natural person whose personal data is processed.
4.2 Personal Data: Any information relating to an identified or identifiable natural person.
4.3 Special Categories of Personal Data: Health information, sexual life, trade union or foundation
membership, and biometric or genetic data.
4.4 Data Processor: A natural or legal person who processes personal data on behalf of the data
controller based on the authority given by the data controller.
5 - RESPONSIBILITY: All hospital staff are responsible.
6 - ACTIVITY FLOW:
6.1 The preservation of data security in storing and sharing patients' personal data within the
institution is essential. The patient may explicitly request secure storage of their personal data.
6.2 Special categories of personal data of patients may not be shared within the institution between
individuals or departments for purposes other than intended use.
6.3 During consultations or examinations with physicians, nurses, and healthcare staff,
communication must ensure that personal data cannot be learned by unauthorized persons.
6.4 Patients' personal data may not be stored on personal phones, computers, or similar electronic
environments belonging to staff. Personal data cannot be shared or disclosed via personal phones,
computers, external email addresses, or social media accounts.
6.5 Unless the patient gives explicit consent, personal data must not be shared with the patient’s
relatives. If legal obligations arise without the patient’s explicit consent, data may only be shared
with the permission of the department head.
6.6 Care must be taken to protect patients' personal data during information exchange between
healthcare staff.
6.7 Printed forms, files, folders, and notebooks containing personal data must not be kept openly
accessible. They should only be stored in a way accessible to relevant personnel.
6.8 Counters, desks, and areas where patient registration or form-filling takes place must ensure
that patient information cannot be seen or heard by others.
6.9 All staff using automation systems, software, portals, and websites must have their own
authorized access credentials, approved by their unit manager, and must not share them with
others.
6.10 Patients' personal data may not be taken outside the institution except for legal obligations.
6.11 If a breach of patients' personal data occurs, the institution will initiate legal proceedings.
7 - RELATED DOCUMENTS