Personal Data Protection

PROSPECTIVE CLIENTS

INFORMATION REGARDING PROCESSING OF PERSONAL DATA OF PROSPECTIVE CLIENTS 

Purpose and legal basis for personal data processing

Program H plus, a.s. processes personal data provided by the prospective clients in particular by filling out the contact forms or via other means of communications as chosen by the prospective client. These personal data are processed based on an express consent or within the performance of the agreement (data necessary in order to prepare and make the agreement).    

The purposes of processing include the performance of the agreement (communication and information exchange prior to the conclusion of the agreement within the necessary scope) and marketing and promotional activities.

Categories of processed data

Program H plus, a.s. processes in particular the following personal data necessary for the conclusion of a contractual relationship or for the purposes of support and promotion of the activities of the company:

• identification details – title, first name and surname, birth name, date of birth, details of the health insurance company etc.,
• contact details – address, phone number, mobile phone number, email address 
• communications records – chat, text messages, emails.

Obtaining personal data

Program H plus, a.s. obtains personal date of prospective clients based on their enquiry for services.

Means and duration of processing of personal data

Processing is carried out by assigned employees both in a written and electronic form. Personal data are processed exclusively in the necessary scope and for the necessary time. The periods of time regarding the deletion and liquidation of personal data are stipulated in the Document Management and Destruction Rules of Program H plus, a.s. under strict compliance with the applicable legislation and the minimisation principle (data are processed solely for the time which is necessary for achieving the specific purpose of processing). The personal data can also be processed by our contracting partners (distribution of the company magazine, IT services and support, marketing support etc.) Processing of personal data carried out by our partners is based on the respective data processing agreements which provide for the specific scope, purposes and means of processing by our partners.       

Transfer of personal data 

Personal data are not transferred to third countries. 

‍Rights of data subjects

Prospective clients have the following rights pertaining to the processing of their personal data: 

• right of access to the processed data and information regarding their processing,
• right to rectification or erasure if the personal data are no longer necessary in relation to the fulfilment of statutory obligations or the provision of agreed services,
• right to restriction of processing, 
• right to object against the processing,
• right to data portability,
• further rights under GDPR.

Prospective clients may assert their rights and requests with the Data protection office using the email address gdpr@programhplus.cz. All demands will be properly assessed and dealt with in compliance with the applicable legislation. If the prospective client does not agree with the resolution of their request, they may lodge a complaint with the Office for Personal Data Protection (Úřad pro ochranu osobních údajů), Pplk. Sochora 27, 170 00 Prague 7.

PATIENTS

INFORMATION REGARDING PROCESSING OF PERSONAL DATA OF PATIENTS

Purpose and legal basis for personal data processing

Program H plus, a.s. obtains and processes personal data relating to the provision of medical and other services in compliance with the applicable legislation, in particular Act no. 372/2011 Coll., on Health Services and Conditions of Their Provision (Act on Health Services), Act no. 373/2011 Coll., on Specific Medical Services, Act no. 48/1997 Coll., on Public Health Insurance, amending and supplementing certain related Acts, etc. Program H plus, a.s.  also processes certain personal data beyond the statutory requirements, this always based on a consent of the patient.  

The purposes for processing include the provision of medical services (specialised ambulatory care and personalised health care), keeping the statutory agenda pertaining to the funding of health care, keeping of the mandatory registers and statistics (health insurance companies etc.), ensuring of safety (CCTV monitoring) or the provision of specific services relating to the provisions of medical services (client zone, mobile app). 

Categories of processed data

Program H plus, a.s. processes in particular the following personal data necessary for the provision of services and the fulfilment of obligations of a medical services provider:  

• identification details – title, first name and surname, birth name, date of birth, number of the personal identification document, nationality etc.
• contact details – address, phone number, mobile phone number, email address
• information regarding the health condition – anamnesis details, information regarding the health condition gained by direct examinations, equipment or laboratory checks, the course and results of examinations and treatments, other relevant circumstances regarding the health condition and the course of action when providing medical care, 
• health insurance details – health insurance company, reporting diagnosis, fulfilment of contractual obligations towards health insurance companies and similar institutions
• communications records (chat, text messages, emails, applications) and other data – information regarding the job position, photos, registration data enabling the access to the client zone and mobile applications, password management, keeping records of access, logs containing information such as IP of the device, type of the device, version of the operation system, configuration of the application upon its usage, date and time of the usage of the application and other statistics, etc. 
• details of contact persons and other persons designated by the patient - first name and surname, date of birth, email address, phone number, relation to the patient. 

Obtaining personal data

Program H plus, a.s. obtains personal data of the patients mainly in relation to the provision of medical services and keeping the medical documentations, or based on contractual relationships or from registers which it uses in connection with the provision of medical services (e.g. information from health insurance companies or national medical registers etc.).  

Means and duration of processing of personal data

Processing is carried out by assigned employees both in a written and electronic form. Personal data are processed exclusively in the necessary scope and for the necessary time. The periods of time regarding the deletion and liquidation of personal data are stipulated in the Document Management and Destruction Rules of Program H plus, a.s. under strict compliance with the applicable legislation and the minimisation principle (data are processed solely for the time which is necessary for achieving the specific purpose of processing). The personal data can also be processed by our contracting partners (distribution of the company magazine, IT services and support, marketing support etc.) Processing of personal data carried out by our partners is based on the respective data processing agreements which provide for the specific scope, purposes and means of processing by our partners.

Transfer of personal data 

Program H plus, a. s. may transfer personal data of patients, including the information regarding the health condition, to cooperating medical services providers (laboratories, hospitals, cooperating doctors or other medical staff) if it is related to the provision of the relevant medical services. In addition, patient’s personal data are transferred to public or private health insurance companies for the purposes of the reimbursement of performed medical services. Certain information is also transferred to the public authorities (e.g. public health office, the national medical register, the Czech Social Security Administration etc.). Information regarding the health condition of the patient may also be disclosed to persons designated by the patient and in the agreed scope.  

Personal data are not transferred to third countries. 

Rights of data subjects

Patients have the following rights pertaining to the processing of their personal data: 

• right of access to the processed data and information regarding their processing,
• right to rectification or erasure if the personal data are no longer necessary in relation to the fulfilment of statutory obligations or the provision of agreed services,
• right to restriction of processing, 
• right to object against the processing,
• right to data portability,
• further rights under GDPR.

Patients may assert their rights and requests with the Data protection office using the email address gdpr@programhplus.cz. All demands will be properly assessed and dealt with in compliance with the applicable legislation. If the patient does not agree with the resolution of their request, they may lodge a complaint with the Office for Personal Data Protection (Úřad pro ochranu osobních údajů), Pplk. Sochora 27, 170 00 Prague 7

EMPLOYEES

INFORMATION REGARDING PROCESSING OF PERSONAL DATA OF EMPLOYEES

Purpose and legal basis for personal data processing

Program H plus, a.s. obtains and processes personal data for the purposes of keeping the employment documents in compliance with the applicable legislation, in particular Act No. 262/2006 Coll., the Labour Code, Act No. 435/2004., on Employment, Act No. 592/1992, on General Health Insurance Premiums and other applicable legislation. Program H plus, a.s.  also processes certain personal data beyond the statutory requirements, this always based on a consent of the employee.  

The purposes for processing include the fulfilment of employer’s duties and obligations (keeping the mandatory employment registers and documents), ensuring of safety (CCTV monitoring) or the provision of benefits and other specific services pertaining to the performance of work.  

Categories of processed data

Program H plus, a.s. processes in particular the following personal data necessary for the fulfilment of the statutory and contractual duties and obligations as the employer:

• identification details – title, first name and surname, personal identification number, number of the personal identification document, bank account number
• personal contact details – address (permanent, temporary), phone numbers, email addresses
• education – school/university reports, diplomas, certificates proving further qualification and trainings, etc. 
• professional CV including work references
• job description – position, workplace 
• occupational and related activities – performed work, shift and on-call work assignment,
• access to PC systems, set-up of access to specific processed personal data  
• access to protected areas  
• working time & attendance tracking
• wage and salary details – remuneration category, provided bonuses, timesheets, amount paid into the bank account, amount paid in cash, annual leave and leave taken, unfitness to work, workplace absence, wage deductions sent to the trade union based on a consent of the trade union member
• details recorded and sent for the purposes of pension insurance
• details provided to the employer for the purposes of checking their income by a bank 
• details provided to bailiffs, courts, the police and other governmental or private organisations if required so by the laws
• health insurance company – reimbursement of the performed medical services
• recording of identification details of a person when entering non-public premises
• assessment regarding fitness for work
• family members details – first name, surname, date of birth, relation as a relative, employer of the spouse, contact details 
• recording of phone calls on selected phone numbers
• communications records (chat, text messages, emails, applications) and other data –photos, password management, keeping records of access, logs containing information such as IP of the device, type of the device, version of the operation system, configuration of the application upon its usage, date and time of the usage of the application and other statistics, etc. 
  

Obtaining personal data

Program H plus, a.s. obtains personal information from employees in connection with keeping the mandatory records and the fulfilment of duties and obligations as the employer, or based on contractual relationships or from registers of institutions Program H plus, a.s. works with when performing its duties and obligations (e.g. health insurance companies, the Czech Social Security Administration etc.). 

Means and duration of processing of personal data

Processing is carried out by assigned employees both in a written and electronic form. Personal data are processed exclusively in the necessary scope and for the necessary time. The periods of time regarding the deletion and liquidation of personal data are stipulated in the Document Management and Destruction Rules of Program H plus, a.s. under strict compliance with the applicable legislation and the minimisation principle (data are processed solely for the time which is necessary for achieving the specific purpose of processing). The personal data can also be processed by our contracting partners (distribution of the company magazine, IT services and support, marketing support etc.) Processing of personal data carried out by our partners is based on the respective data processing agreements which provide for the specific scope, purposes and means of processing by our partners.       

Transfer of personal data 

Program H plus, a. s. may transfer personal data of employees to financial and social administration authorities, health insurance companies of the employees and other offices and institutions as required under the applicable legislation. Certain personal data processed within the agenda of employees’ benefits may be transferred to providers of specific services (meal vouchers, education, travel agencies, leisure activities etc.).   

Personal data are not transferred to third countries. 

Rights of data subjects

Employees have the following rights pertaining to the processing of their personal data: 

• right of access to the processed data and information regarding their processing,
• right to rectification or erasure if the personal data are no longer necessary in relation to the fulfilment of statutory obligations or the provision of agreed services,
• right to restriction of processing, 
• right to object against the processing,
• right to data portability,
• further rights under GDPR.

Employees may assert their rights and requests with the Data protection office using the email address gdpr@programhplus.cz. All demands will be properly assessed and dealt with in compliance with the applicable legislation. If the employee does not agree with the resolution of their request, they may lodge a complaint with the Office for Personal Data Protection (Úřad pro ochranu osobních údajů), Pplk. Sochora 27, 170 00 Prague 7.

CONTRACTING PARTNERS

INFORMATION REGARDING PROCESSING OF PERSONAL DATA OF CONTRACTING PARTNERS

Purpose and legal basis for personal data processing

In order to ensure certain intern processes, the operation of the policlinic and the performance of its contractual obligations, Program H plus, a.s. processes the personal data of its contracting partners, individuals, its contracting partners representatives and legal entities. The legal basis for the processing is the performance of the contractual obligations or a granted consent.  

Categories of processed data

Program H plus, a.s. processes the following personal data of contracting partners mainly in connection with the fulfilment of contractual obligations.  

• identification details – title, first name and surname, date of birth, etc.,
• contact details – address, phone number, mobile phone number, email address 
• company identification number, registered office 
• bank details
• job description
• communications records (chat, text messages, emails, applications) and other date- photos, password management etc.
  

Obtaining personal data

Program H plus, a.s. obtains personal data from contracting partners mainly in connection with the fulfilment of contractual obligations.  

Means and duration of processing of personal data

Processing is carried out by assigned employees both in a written and electronic form. Personal data are processed exclusively in the necessary scope and for the necessary time. The periods of time regarding the deletion and liquidation of personal data are stipulated in the Document Management and Destruction Rules of Program H plus, a.s. under strict compliance with the applicable legislation and the minimisation principle (data are processed solely for the time which is necessary for achieving the specific purpose of processing). The personal data can also be processed by our contracting partners (distribution of the company magazine, IT services and support, marketing support etc.) Processing of personal data carried out by our partners is based on the respective data processing agreements which provide for the specific scope, purposes and means of processing by our partners.       

Transfer of personal data 

Personal data are not transferred to third countries. 

Rights of data subjects

Contracting partners have the following rights pertaining to the processing of their personal data: 

• right of access to the processed data and information regarding their processing,
• right to rectification or erasure if the personal data are no longer necessary in relation to the fulfilment of statutory obligations or the provision of agreed services,
• right to restriction of processing, 
• right to object against the processing,
• right to data portability,
• further rights under GDPR.

Contracting partners may assert their rights and requests with the Data protection office using the email address gdpr@programhplus.cz. All demands will be properly assessed and dealt with in compliance with the applicable legislation. If the contracting partner does not agree with the resolution of their request, they may lodge a complaint with the Office for Personal Data Protection (Úřad pro ochranu osobních údajů), Pplk. Sochora 27, 170 00 Prague 7.