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Data Protection Policy
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OBJECTIVE AND SCOPE
To establish, define, and regulate the parameters for the handling and administration of the personal data of patients, beneficiaries, employees, suppliers, and other data stored in databases owned by Clínica Colombiana de Implantes Dentales S.A., whether in physical or automated form.
RESPONSIBLE PARTY
Clínica Colombiana de Implantes Dentales S.A., Tax ID No. 890.941.638-5, located at Trans. 34 N.72-160 main office, Medellín city, email: info@clinicacolombianadeimplantes.com
JUSTIFICATION
This policy is governed in compliance with Article 15 of the Political Constitution of Colombia, Law 1581 of 2012, and other regulatory decrees and standards that establish general provisions for the protection of personal data, which shall be applied harmoniously and comprehensively.
DEFINITIONS
- Database: A set of data belonging to the same context and systematically stored for later use.
- Personal Data: Any information linked or that may be associated with one or more identified or identifiable natural persons.
- Data Subject: Natural person whose personal data is subject to processing.
- Processing: Any operation or set of operations performed on personal data, such as collection, storage, use, circulation, or deletion.
- Authorization: Prior, express, and informed consent given by the Data Subject to carry out the processing of personal data.
- Sensitive Data: Data affecting the privacy of the Data Subject or whose improper use may lead to discrimination, such as data revealing racial or ethnic origin, political orientation, religious or philosophical beliefs, membership in unions or social organizations, health-related information, sexual life, and biometric data.
- Data Controller: Natural or legal person designated by Clínica Colombiana de Implantes Dentales S.A. as responsible for the processing of databases and/or the processing of data stored within the entity.
- Privacy Notice: Physical, electronic, or any other format document prepared by Clínica Colombiana de Implantes Dentales S.A. and made available to the Data Subject to inform them about the processing of their personal data.
PRINCIPLES
Clínica Colombiana de Implantes Dentales shall apply systematically and comprehensively the principles established in Law 1581 of 2012 and Decrees 1377 of 2013 and 866 of 2015 for the processing and management of personal data stored within the entity.
a. Legality in Data Processing: Clínica Colombiana de Implantes Dentales shall comply with the laws and regulations established for the processing and management of personal data.
b. Purpose: Data processing must obey a legitimate purpose in accordance with the Constitution and the Law, which must be informed to the Data Subject.
c. Freedom: Data processing may only be carried out with the prior, express, and informed consent of the Data Subject.
d. Accuracy or Quality: Information subject to processing must be truthful, complete, accurate, updated, verifiable, and understandable.
e. Transparency: The Data Subject has the right to obtain information regarding the existence of data concerning them at any time.
f. Restricted Access and Circulation: Processing is subject to the limits derived from the nature of personal data and legal provisions.
g. Security Principle: Information subject to processing shall be managed with the necessary technical, human, and administrative measures to ensure security.
h. Confidentiality: All persons involved in the processing of personal data are obligated to guarantee the confidentiality of the information.
RIGHTS OF DATA SUBJECTS
The Data Subject shall have the following rights:
a. To know, update, and rectify their personal data.
b. To request proof of the authorization granted for data processing.
c. To be informed about the use given to their personal data.
d. To file complaints before the Superintendence of Industry and Commerce.
e. To revoke authorization and/or request the deletion of personal data.
f. To access their personal data free of charge.
AUTHORIZATION AND PROOF OF USE OF PERSONAL DATA
Without prejudice to the exceptions provided by law, Clínica Colombiana de Implantes Dentales shall require prior, free, express, and informed authorization from the Data Subject for the collection, storage, or deletion of personal data.
MECHANISMS TO GRANT AUTHORIZATION
Authorization may be contained in a physical or electronic document or in any other format that guarantees its subsequent consultation.
EVENTS IN WHICH AUTHORIZATION IS NOT REQUIRED
Authorization from the Data Subject shall not be required when dealing with:
a) Information required by a public or administrative entity in the exercise of its legal functions or by court order.
b) Public data.
c) Information processing authorized by law for historical, statistical, or scientific purposes.
REVOCATION OF AUTHORIZATION
Data Subjects may revoke consent for the processing of their personal data at any time, provided that no legal or contractual provision prevents it.
PRIVACY NOTICE
Clínica Colombiana de Implantes Dentales shall inform the Data Subject about the existence of its information processing policies and procedures.
MINIMUM CONTENT OF THE PRIVACY NOTICE
The privacy notice shall contain at least the following information:
a. Identity, address, and contact information of the Data Controller.
b. The type and purpose of data processing.
c. Mechanisms available for the Data Subject to access the data processing policy.
d. Information on how to consult the information processing policy.
CONSULTATIONS
Data Subjects may submit written requests to access their personal information.
CLAIMS
Data Subjects who consider that the information contained in the database should be corrected, updated, or deleted may file a claim with Clínica Colombiana de Implantes Dentales.
DATA UPDATE
At any time and free of charge, the Data Subject may request the correction, update, or deletion of their personal data.
DATA DELETION
The Data Subject may request the deletion of their personal data when it is not being processed according to the principles and obligations established by law.
AREA RESPONSIBLE FOR DATA PROTECTION
Clínica Colombiana de Implantes Dentales designates the Human Resources Department, Medical Records Committee, Quality Committee, and Systems Department as responsible for personal data protection.
INTERNATIONAL DATA TRANSFERS
By accepting this Personal Data Protection Manual, the Data Subject authorizes Clínica Colombiana de Implantes Dentales S.A. to transfer personal data nationally or internationally within the applicable legal framework.
EFFECTIVE DATE:
This manual is effective as of November 2016.
OBJECTIVE AND SCOPE
To establish, define, and regulate the parameters for the handling and administration of the personal data of patients, beneficiaries, employees, suppliers, and other data stored in databases owned by Clínica Colombiana de Implantes Dentales S.A., whether in physical or automated form.
RESPONSIBLE PARTY
Clínica Colombiana de Implantes Dentales S.A., Tax ID No. 890.941.638-5, located at Trans. 34 N.72-160 main office, Medellín city, email: info@clinicacolombianadeimplantes.com
JUSTIFICATION
This policy is governed in compliance with Article 15 of the Political Constitution of Colombia, Law 1581 of 2012, and other regulatory decrees and standards that establish general provisions for the protection of personal data, which shall be applied harmoniously and comprehensively.
DEFINITIONS
- Database: A set of data belonging to the same context and systematically stored for later use.
- Personal Data: Any information linked or that may be associated with one or more identified or identifiable natural persons.
- Data Subject: Natural person whose personal data is subject to processing.
- Processing: Any operation or set of operations performed on personal data, such as collection, storage, use, circulation, or deletion.
- Authorization: Prior, express, and informed consent given by the Data Subject to carry out the processing of personal data.
- Sensitive Data: Data affecting the privacy of the Data Subject or whose improper use may lead to discrimination, such as data revealing racial or ethnic origin, political orientation, religious or philosophical beliefs, membership in unions or social organizations, health-related information, sexual life, and biometric data.
- Data Controller: Natural or legal person designated by Clínica Colombiana de Implantes Dentales S.A. as responsible for the processing of databases and/or the processing of data stored within the entity.
- Privacy Notice: Physical, electronic, or any other format document prepared by Clínica Colombiana de Implantes Dentales S.A. and made available to the Data Subject to inform them about the processing of their personal data.
PRINCIPLES
Clínica Colombiana de Implantes Dentales shall apply systematically and comprehensively the principles established in Law 1581 of 2012 and Decrees 1377 of 2013 and 866 of 2015 for the processing and management of personal data stored within the entity.
a. Legality in Data Processing: Clínica Colombiana de Implantes Dentales shall comply with the laws and regulations established for the processing and management of personal data.
b. Purpose: Data processing must obey a legitimate purpose in accordance with the Constitution and the Law, which must be informed to the Data Subject.
c. Freedom: Data processing may only be carried out with the prior, express, and informed consent of the Data Subject.
d. Accuracy or Quality: Information subject to processing must be truthful, complete, accurate, updated, verifiable, and understandable.
e. Transparency: The Data Subject has the right to obtain information regarding the existence of data concerning them at any time.
f. Restricted Access and Circulation: Processing is subject to the limits derived from the nature of personal data and legal provisions.
g. Security Principle: Information subject to processing shall be managed with the necessary technical, human, and administrative measures to ensure security.
h. Confidentiality: All persons involved in the processing of personal data are obligated to guarantee the confidentiality of the information.
RIGHTS OF DATA SUBJECTS
The Data Subject shall have the following rights:
a. To know, update, and rectify their personal data.
b. To request proof of the authorization granted for data processing.
c. To be informed about the use given to their personal data.
d. To file complaints before the Superintendence of Industry and Commerce.
e. To revoke authorization and/or request the deletion of personal data.
f. To access their personal data free of charge.
AUTHORIZATION AND PROOF OF USE OF PERSONAL DATA
Without prejudice to the exceptions provided by law, Clínica Colombiana de Implantes Dentales shall require prior, free, express, and informed authorization from the Data Subject for the collection, storage, or deletion of personal data.
MECHANISMS TO GRANT AUTHORIZATION
Authorization may be contained in a physical or electronic document or in any other format that guarantees its subsequent consultation.
EVENTS IN WHICH AUTHORIZATION IS NOT REQUIRED
Authorization from the Data Subject shall not be required when dealing with:
a) Information required by a public or administrative entity in the exercise of its legal functions or by court order.
b) Public data.
c) Information processing authorized by law for historical, statistical, or scientific purposes.
REVOCATION OF AUTHORIZATION
Data Subjects may revoke consent for the processing of their personal data at any time, provided that no legal or contractual provision prevents it.
PRIVACY NOTICE
Clínica Colombiana de Implantes Dentales shall inform the Data Subject about the existence of its information processing policies and procedures.
MINIMUM CONTENT OF THE PRIVACY NOTICE
The privacy notice shall contain at least the following information:
a. Identity, address, and contact information of the Data Controller.
b. The type and purpose of data processing.
c. Mechanisms available for the Data Subject to access the data processing policy.
d. Information on how to consult the information processing policy.
CONSULTATIONS
Data Subjects may submit written requests to access their personal information.
CLAIMS
Data Subjects who consider that the information contained in the database should be corrected, updated, or deleted may file a claim with Clínica Colombiana de Implantes Dentales.
DATA UPDATE
At any time and free of charge, the Data Subject may request the correction, update, or deletion of their personal data.
DATA DELETION
The Data Subject may request the deletion of their personal data when it is not being processed according to the principles and obligations established by law.
AREA RESPONSIBLE FOR DATA PROTECTION
Clínica Colombiana de Implantes Dentales designates the Human Resources Department, Medical Records Committee, Quality Committee, and Systems Department as responsible for personal data protection.
INTERNATIONAL DATA TRANSFERS
By accepting this Personal Data Protection Manual, the Data Subject authorizes Clínica Colombiana de Implantes Dentales S.A. to transfer personal data nationally or internationally within the applicable legal framework.
EFFECTIVE DATE:
This manual is effective as of November 2016.
CLINICACOLOMBIANA DE IMPLANTES DENTALES is committed to promoting a culture of humanized care among its staff, based on warmth in service, mutual respect, effective communication, privacy, confidentiality, and patient safety in healthcare delivery. This commitment is carried out through awareness initiatives, training programs, and teamwork practices that engage the entire healthcare and administrative team in creating a unique and unforgettable experience for patients and their families.
CLINICACOLOMBIANA DE IMPLANTES DENTALES is committed to promoting a culture of humanized care among its staff, based on warmth in service, mutual respect, effective communication, privacy, confidentiality, and patient safety in healthcare delivery. This commitment is carried out through awareness initiatives, training programs, and teamwork practices that engage the entire healthcare and administrative team in creating a unique and unforgettable experience for patients and their families.
The IPS is committed to implementing best safety practices in healthcare services and improving the quality of its processes. Patient safety is considered one of its top priorities in the care process, both in general and specialized dentistry. To achieve this, the IPS promotes a culture of safety among its staff, patients, and families through ongoing training and motivation for the implementation of safe healthcare practices, while developing actions for the identification, prevention, and management of risks related to the healthcare process, aimed at reducing the incidence of incidents and adverse events, thereby creating a safe environment for everyone.
ACTIONS FOR THE PREVENTION OF INFECTIONS ASSOCIATED WITH HEALTHCARE SERVICE DELIVERY
- Use of gloves.
- Use of sterile gowns and sterile drapes ?? Surgery.
- Antimicrobial prophylaxis.
- Use of personal protective equipment.
- Intensive cleaning of clinical care areas.
- Deep disinfection of dental units.
- Use of closed containers for the transport of instruments and hospital waste.
- Proper sterilization techniques.
- Use of appropriate containers for disposal of contaminated and sharp materials.
- Use of sterile disposable materials.
- Spill management.
- Handwashing at the 5 moments.
PATIENT FALL PREVENTION
Measures:
- Care for patients with reduced mobility and patients over 70 years old on the first floor.
- Assistance by the dental assistant after surgeries, lengthy procedures, or for anxious patients.
- Requesting a companion for surgery procedures.
- Identification in appointment scheduling notes (alert) for high fall risk patients.
- Medical record: scales may be added.
CORRECT PATIENT IDENTIFICATION
- Training on required patient information (as required by the medical record).
- Updating or verifying this information in the medical record.
- Taking a patient photograph.
- At reception, the patient??s name must be confirmed before marking attendance confirmation in the system.
- In the office, prior to providing the service, the professional verifies the patient??s identity by asking for their full first and last names and confirming this information against the medical record and photograph.
The IPS is committed to implementing best safety practices in healthcare services and improving the quality of its processes. Patient safety is considered one of its top priorities in the care process, both in general and specialized dentistry. To achieve this, the IPS promotes a culture of safety among its staff, patients, and families through ongoing training and motivation for the implementation of safe healthcare practices, while developing actions for the identification, prevention, and management of risks related to the healthcare process, aimed at reducing the incidence of incidents and adverse events, thereby creating a safe environment for everyone.
ACTIONS FOR THE PREVENTION OF INFECTIONS ASSOCIATED WITH HEALTHCARE SERVICE DELIVERY
- Use of gloves.
- Use of sterile gowns and sterile drapes ?? Surgery.
- Antimicrobial prophylaxis.
- Use of personal protective equipment.
- Intensive cleaning of clinical care areas.
- Deep disinfection of dental units.
- Use of closed containers for the transport of instruments and hospital waste.
- Proper sterilization techniques.
- Use of appropriate containers for disposal of contaminated and sharp materials.
- Use of sterile disposable materials.
- Spill management.
- Handwashing at the 5 moments.
PATIENT FALL PREVENTION
Measures:
- Care for patients with reduced mobility and patients over 70 years old on the first floor.
- Assistance by the dental assistant after surgeries, lengthy procedures, or for anxious patients.
- Requesting a companion for surgery procedures.
- Identification in appointment scheduling notes (alert) for high fall risk patients.
- Medical record: scales may be added.
CORRECT PATIENT IDENTIFICATION
- Training on required patient information (as required by the medical record).
- Updating or verifying this information in the medical record.
- Taking a patient photograph.
- At reception, the patient??s name must be confirmed before marking attendance confirmation in the system.
- In the office, prior to providing the service, the professional verifies the patient??s identity by asking for their full first and last names and confirming this information against the medical record and photograph.