Policy on Storage and Protection of Special Personal Data

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DR. MEHMET CÖMERT

POLICY ON STORAGE AND PROTECTION OF SPECIAL PERSONAL DATA

Purpose and Scope of the Policy

Personal Data Protection Law No. 6698 entered into force on April 7, 2016; This policy Dr. Mehmet Cömert ensures compliance with the Law on the Protection of Special Personal Data and Dr. It aims to determine the principles to be followed by Mehmet Cömert in fulfilling its obligations regarding the protection and processing of special personal data.

The Policy determines the processing conditions of special categories of personal data and Dr. It reveals the main principles adopted by Mehmet Cömert. In this context, Politics, Dr. All personal data processing activities within the scope of the Law by Mehmet Cömert, Dr. It covers the owners of all personal data processed within the scope of Mehmet Cömert's professional activities and all personal data processed.

Effectiveness and Change

Politics, Dr. It was published on the website by Mehmet Cömert and presented to the public. In case of conflict between the current legislation, especially the Law, and the regulations contained in this Policy, the provisions of the legislation shall apply.

Dr. Mehmet Cömert reserves the right to make changes to the Policy in parallel with legal regulations.

Special Personal Data

It refers to data regarding religion, health, criminal convictions and security measures.

Processing of Special Personal Data

Dr. Mehmet Cömert strictly complies with the regulations stipulated in the Law in the processing of personal data determined as "special nature" by the Law. In Article 6 of the Law, some personal data that poses the risk of causing victimization or discrimination when processed unlawfully are designated as "special nature". These data are data regarding religion, health, criminal convictions and security measures.

In accordance with the law, Dr. By Mehmet Cömert; Special categories of personal data are processed in the following cases, provided that adequate measures are taken to be determined by the KVK Board:

If the personal data owner has explicit consent or

If there is no explicit consent of the personal data owner;

Special categories of personal data other than the health of the personal data owner, in cases stipulated by law, Special personal data regarding the health of the personal data owner, only for the purpose of protecting public health, carrying out preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and their financing. It is processed by persons or authorized institutions and organizations who are under the obligation of confidentiality.

Transfer of Special Personal Data

Dr. Mehmet Cömert takes the necessary care, takes the necessary security measures and takes the adequate precautions prescribed by the KVK Board; In line with legitimate and lawful personal data processing purposes, the personal data owner's special personal data may be transferred to third parties in the following cases.

If the personal data owner has explicit consent or

If there is no explicit consent of the personal data owner;

Special categories of personal data other than the health of the personal data owner (data related to religion, criminal convictions and security measures), in cases stipulated by law,

Special personal data regarding the health and sexual life of the personal data owner can only be used by persons or authorized institutions and organizations under the obligation of confidentiality for the purpose of protecting public health, carrying out preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and their financing. can be transferred by.

Transfer of Special Personal Data Abroad

Dr. Mehmet Cömert takes the necessary care, takes the necessary security measures and takes the adequate precautions prescribed by the KVK Board; In line with legitimate and lawful personal data processing purposes, the special data of the personal data owner may be transferred to Foreign Countries Where the Data Controller Has Adequate Protection or Undertakes Adequate Protection in the following cases:

If the personal data owner has explicit consent or

If there is no explicit consent of the personal data owner;

Special personal data other than the health and sexual life of the personal data owner (data regarding race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and dress, association, foundation or union membership, criminal conviction and security measures and biometric and genetic data), in cases stipulated by law,

Protection of Special Personal Data

Dr. Mehmet Cömert acts with care in protecting special personal data, which are determined as "special nature" by the Law and processed in accordance with the law. In this context, the technical and administrative measures taken by our clinic to protect personal data are carefully implemented in terms of special personal data and the necessary inspections are provided within our clinic.

In addition, technical and administrative measures are taken to ensure the appropriate level of security with the measures determined by the Personal Data Protection Board in terms of special personal data.

Dr. Mehmet Cömert's general principle is that it does not process special personal data unless there are reasons arising from the law.

Non-essential sensitive personal data is deleted or blacked out. Based on this, systematic rules for the security of special personal data are determined in this policy;

Precautions for Employees Involved in the Processing of Special Personal Data

Regular training is provided on special personal data security issues in accordance with the law and related regulations.
Confidentiality agreements are signed.
The authorization scopes and authorization processes of users who have access to data are defined by the authorization matrix.
Authorization checks are carried out periodically.
The authorizations of employees who change their duties or leave their jobs in these areas are immediately removed.

For Electronic Environments Where Special Personal Data Are Processed and Stored

Security updates for the environments where data is stored are constantly monitored.
If the data is accessed through software, user authorization for this software is made.

For Physical Environments Where Special Personal Data Are Processed and Stored

Necessary security measures are taken regarding entry and exit to physical environments containing sensitive personal data.
The security of physical environments containing sensitive personal data against external risks (fire, flood, etc.) is ensured.

Precautions Regarding the Transfer of Special Personal Data

When transferring on paper, necessary precautions are taken against risks such as theft, loss, or viewing of documents by unauthorized persons, and the documents are sent in a sealed envelope in the "confidential documents" format.