Certific’s doctor-patient communication platform| Privacy Policy

Welcome to Certific's doctor-patient communication platform !

1. Important information about who we are

We are Certific OÜ (“ Certific ”, “ we ” or “ we ”) with a registered address at registry code: 16050394, address: Volta 1, Tallinn 10411, Estonia.  

We provide a doctor-patient communication environment service at perearst.certific.co (“Platform” or “Service ”).  In order to make personal data related principles understandable to all parties when using the Platform, we have described below the privacy policy of the service (“Privacy Policy”). This Privacy Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.  

To better understand our Services, please read our terms and conditions of the Services (“Terms and Conditions”) in advance. The Platform can only be used by accepting the Terms and Conditions.

We keep our privacy policy under regular review. This version was last updated on [10 March 2023]  It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. Concepts

a) User(s): Healthcare Provider employees, their patients and other persons using the platform.

b) Certific : Platform service provider.

c) Healthcare Provider: Healthcare Provider to the patient via the platform.

d) Employee of a Healthcare Provider: an employee of a Healthcare Provider who uses the platform to communicate with patients on behalf of the Healthcare Provider and whose personal data may be processed through the platform in a limited amount.

e) Patients: patients who use the platform to communicate with a Healthcare Provider, and whose personal data (including health-related data) is processed through the Platform.

2. Who is responsible for your personal data

a) For the purposes of the EU Data Protection Regulation (EU Regulation 697/2016) (“the GDPR”), the Healthcare Provider is the data controller with regard to personal data described in this Privacy Policy relating to a patient or an employee of the Health Service Provider.

b) “Data controllers” are the people who or organisations which determine the purposes for which, and the manner in which, any personal data is processed, who/which make independent decisions in relation to the personal data and/or who/which otherwise control that personal data.

c) The health care service provider processes the personal data of the patient (and its own employee) primarily for the purpose of providing health care services to the patient and is responsible for the provision of health care services and the processing of personal data accompanying the provision of health care services.

d) As a platform service provider, Certific is a processor of personal data for a Healthcare Provider.

3. The data we collect about you.

a) “Personal data” means any information relating to an identified or identifiable natural person. Personal data can be factual (for example, a name, address or date of birth) or it can be an opinion about that person, their actions and/or behavior.

b) Certific may process the following personal data on behalf of the Healthcare Provider, to the extent that it is necessary to provide the platform service to the Healthcare Provider:

• the patient's name, contact details, personal identification number or other data enabling identification of the patient;
• patient's health data (information disclosed by the patient to the Healthcare Provider during the use of the platform, including answers to questionnaires, photos, files) (“Patient Data”)
• personal data of the employee of the Healthcare Provider (name, contact details and personal identification number) and data entered into the platform by the Healthcare Provider (e.g., diagnosis) (“Service Provider Data”)

c) Certific may perform the following data processing operations on behalf of the Healthcare Provider with the personal data specified in the above point:

• data management and mediation to enable communication between Healthcare Provider and patient;
• data analysis (including for conducting feedback questionnaires);
• other arrangements of the Healthcare Provider.

4. How do we collect your personal data?

We collect personal data from the Health Care Provider and the Patient when employees of the Health Care Provider and patients are using the platform.

5. What are the bases and purposes for the processing of personal data based on which we as an authorised processor proceed?

a) Certific and the healthcare services provider have entered into a contract which ensures the legality and security of personal data processing.

b) We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

    i) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

6. Purposes for which we use your personal data 

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing
To register the Service Provider on the Platform	Service Provider Data	a) Performance of our contract with the Healthcare Provider
To communicate with Healthcare Providers and Patients with regard to queries about the Platform	Service Provider Data Patient Data	a) Necessary for our legitimate interests b) Performance of our contract with Healthcare Providers
To manage our relationship with the Healthcare Provider which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey	Service Provider  Data	a) Performance of a contract with our Healthcare Provider b) Necessary to comply with a legal obligation  c) Necessary for our legitimate interests (to keep our records updated and to study how Service Providers use our services)

7. How do we store personal data and when do we transfer it?

a) When storing personal data, as a processor, we proceed from the validity of the contract concluded with the responsible processor and store personal data from the moment we conclude a contract with the Healthcare Provider and until the moment when we no longer process personal data on behalf of the Healthcare Provider.

b) We do not transfer personal data to third parties, except to the extent that it is necessary to provide the platform service to the health care provider and to the extent we have agreed with the Healthcare Provider.

c) We do not transfer personal data outside the European Economic Area and the UK. 

8. Security

a) We take appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data. We limit access to your personal data to those employees, agents and other third parties who are required to have access to your personal data and where they have agreed that they are subject to a duty of confidentiality. We regularly upgrade our systems in terms of information security and consistently train our employees on data protection topics.

b) We have put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction.  We have procedures in place to deal with actual and suspected data breaches which include an obligation on us to notify the supervisory authority and/or you, the data subject, where legally required to do so.

9. Rights related to personal data

a) The users of the platform are guaranteed all the rights prescribed by law in the processing of personal data, including the following:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: 
• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. 
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

b) In order to exercise your rights, you must contact the controller of personal data, i.e., the Healthcare Provider.

c) In the event that you wish to make a complaint about how your personal data is being processed by us, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority who can be contacted as follows. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance: 

Contact	Data Protection Commission
Telephone	+353 57 8684800 / +353 761 104 800
Email	info@dataprotection.ie
Post	Data Protection Commission 21 Fitzwilliam Square South Dublin 2 D02 RD28 Ireland

10. Other provisions

a) Certific has appointed a data protection specialist to deal with questions related to personal data, who can be contacted at dpo@certific.co .