Privacy statements
Privacy statements
1. Definition
We use specific terms and abbreviations in this privacy statement, some of which are described below:
KHS: KLM Health Services
AMS: Airport Medical Services, a subsidiary of KLM Health Services
Personal data: data that relates to you directly or indirectly. For example, your name, address and medical data
Processing: this refers to everything that can be done with your personal data. This includes gathering data, but it may also refer to storage, utilisation and deletion of your data from our systems
GDPR: Regulation (EU) 2016/679 (General Data Protection Regulation)
Customers: Contracting organisations that engage KHS and/or AMS to perform services, such as employers as well as the natural persons to whom the services provided by KHS and/or AMS relate directly.
2. For whom do KHS and AMS process personal data?
We process the personal data of people with whom we have (or have had) a direct or indirect relationship. This includes, for example, the personal data of staff members, job applicants, potential and existing customers, the next-of-kin of our customers, visitors to our website and/or the employees of suppliers.
3. Responsibility for processing personal data
KHS and AMS are responsible for processing all your data. Any reference to KHS and AMS in this privacy statement extends to all staff members of all establishments and departments of KHS and AMS where personal data is processed.
We undertake to only process legally obtained data provided by you, your employer or third parties and for which you or your employers have requested that KHS or AMS process said data. Responsibility for the accuracy of the information provided lies with you, your employer and/or the third parties concerned.
After receiving the personal data, we then bear responsibility for further processing in the context of GDPR, which includes the storage of personal data in the file.
We will process personal data in accordance with our policy pertaining to the processing of personal data and only insofar as this is necessary, based on:
(1) compliance with legal obligations
(2) entering into and executing an agreement
(3) representing the legitimate interests of KHS and/or AMS or
(4) receiving your express permission
We guarantee that based on these provisions, your data will be processed in accordance with the purposes mentioned below for which you have provided the data, and that we will only process your personal data for these specific purposes.
4. Processing personal data
We process personal data for the following purposes:
a. To enter into relations with you as a customer
If you register with KHS and/or AMS with a request for a particular service, we need your personal data. This includes obvious details such as your name, address and place of residence as well as data needed to provide the service requested.
b. To maintain relations with you and carry out assignments
We aim to offer you the best possible service as a customer. To this end, we process your personal data. We use your name, address or telephone number to contact you or to remind you of an appointment for example, or occasionally we may use these details for a customer satisfaction survey aimed at improving our services.[1] We also use customer data anonymously that cannot be traced back to an individual to generate group reports. The group reports are used to identify health trends to substantiate health policy advice for organisations and/or to optimise our services, therefore continuing to meet customer wishes and requirements.
[1] Anonymous data is used to carry out the survey.
c. For internal and external consultation
In some cases, our staff need to consult with a colleague or external specialist (e.g. a hospital physician).
d. For financial processing
We need your information to settle payment for services rendered, either with yourself or with your health insurance provider. In the case of occupational health services, we will need to settle with your employer.
e. To guarantee your safety and ours
Security cameras have been installed at a number of our establishments to guarantee your safety and ours. There are no cameras in our treatment rooms.
f. To establish and carry out agreements with suppliers
If either you or your employer have a supplier contract with KHS and/or AMS, we will need to process your personal data. For example, to enable you to access our establishments when carrying out short-term assignments.
g. For our business operations
As a service provider, it is necessary for us to maintain a good overview of our customer relations. Processing your data makes it possible for us to comply with the legal requirements as stipulated in the Medical Treatment Agreement Act (WGBO), the Utilisation of Citizen Service Numbers in Healthcare Act and the Guidelines of the Royal Dutch Medical Association (KNMG). If we collect information about your website visit via cookies, this is included in our cookie statement.
h. For the purpose of (entering into) employment
If you respond to a vacancy, we process your personal data as a job applicant for the purpose of the application procedure. On entering into an employment contract, we process personal data of our staff members in order to fulfil our obligations as an employer.
If we wish to use your personal data for any purpose other than that for which it was originally processed, we may only do so if the two purposes are closely connected. We will not process your data further if this is incompatible with the original purpose. If we wish to process your traceable data for scientific research or statistical purposes, we will inform you accordingly and implement appropriate safeguards in accordance with GDPR.
5. Special categories of personal data
Sensitive data constitutes a special category. Sensitive data are those relating to your health. Only if strictly necessary, we process personal data in this category about your health to perform effectively in our capacity as a healthcare or service provider. We only process such data if this is required by legislation and regulations, or on the basis of your request or explicit consent. If you ask us to record your personal data or if you choose to make your data publicly available, we will only process such data if it is essential for providing our services.
6. Sharing personal data
KHS and AMS engage suppliers, partner organisations and other third parties for the purposes of service provision and maintaining business operations. It may be necessary to share personal data with these parties. In all cases, KHS and AMS only provide the necessary data and only if there is a legitimate basis for doing so, such as complying with legal obligations, executing an agreement or with your consent.
Examples here include:
Suppliers forming part of our (internal) services
Other healthcare providers to whom we may refer you
Partner organisations for performing medical diagnostic examinations
- Third parties for the purpose of accountability
7. Protection of personal data
KHS and AMS make every effort to optimally secure your personal data against unlawful use. At KHS and AMS, your personal data is secured in accordance with national standards, which implies that your (medical) data will only be accessible to KHS/AMS staff providing you with treatment or support. Our staff sign confidentiality agreements and are not permitted to share information with unauthorised persons, even after they have terminated their employment with us. KHS and AMS hold valid ISO 27001 and NEN 7510 certificates.
If KHS and/or AMS should enter into a cooperative relationship where your personal data needs to be processed by another organisation, KHS and/or AMS will ensure that appropriate agreements are reached to safeguard the security, processing and storage of your personal data as part of that relationship.
If, despite all the legal, technical and procedural measures taken, a situation should arise in which we cannot guarantee your privacy, we will immediately report this to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) and inform you of the situation regarding your data.
8. Data retention periods
Your personal data will not be retained longer than necessary for the purpose for which it was processed. KHS and AMS adhere to legally and internally prescribed retention periods.
9. Rules for the processing of personal data
When processing personal data, KHS and AMS must comply with the applicable legislation and regulations, including the General Data Protection Regulation (GDPR), the Medical Treatment Agreement Act (WBGO), the Utilisation of Citizen Service Numbers in Healthcare Act, the Health Insurance Act (Zorgverzekeringswet), the Absenteeism Reduction Act (Wet Poortwachter), the Working Conditions Decree, the General Tax Act and the Guidelines of the Royal Dutch Medical Association (KNMG).
10. Your rights
Because we process your personal data, you have the following rights:
The right to view, correct and delete your data, which includes the right to be forgotten, unless the retention of such data could be of significant importance to third parties or if deleting such data is legally prohibited
- The right to withdraw consent for processing your personal data
The right to object to data processing. This could make it difficult or even impossible for us to provide the services you require
The right to have your personal data forwarded to yourself or other specified organisations
You can submit such requests via our website or via the email address below.
11. Questions or complaints
If you have general questions about the processing of your personal or medical data by KHS and AMS, you can send them to us at the email address below.
If KHS and/or AMS do not provide a satisfactory answer or deal with your complaint in a satisfactory manner, you may contact the Personal Data Authority. You will find all the contact details below.
Contact details
• Questions about processing of your personal or medical data by KHS and AMS should be sent to: [email protected]
• If you have a complaint, please submit it using our online complaints form on the website.
• Website of the Personal Data Authority: www.autoriteitpersoonsgegevens.nl
12. Revision of this document
This privacy statement may be revised from time to time. You will always find the latest version of our privacy statement on our website: https:www.klmhealthservices.com
Last update: December 2023