Remote service for eligible medical-tourism organisationsTürkiye · Europe · Dubai/Gulf

TOPIC

Patient Data and Privacy

Health data is special-category personal data and can be collected unknowingly through digital communication channels. This topic brings together the pages covering the data-flow map, the consent structure and team behaviour.

In medical tourism first contact often begins with a message and an image. The moment a patient sends an X-ray, institutional data responsibility has effectively begun, usually with no notice given.

The data-flow map comes first

Most institutions do not know precisely which data arrives through which channel. Web form, WhatsApp, Instagram messages, the call centre, facilitator referrals and advertising-platform forms all operate independently.

Mapping makes the sprawl visible: for each channel, the data collected, where it is stored, who can access it, the retention period and the deletion method are written in one table. Without that table, an updated privacy notice does not reflect reality.

Notice and explicit consent are not the same

The notice obligation applies in every case and means informing the individual. Explicit consent is a specific, informed and freely given approval for a defined processing activity.

Folding both into one tickbox is where most institutions slip. Informing someone is not the same as obtaining their agreement, and the agreement half has to stand alone, stay optional and be reversible in practice.

Pages under this topic

Page

Personal Data Notice

Data controller identity, processing purposes, legal grounds, transfers and data subject rights under Turkish data protection law.

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Frequently asked questions

What institutions ask about this topic

A patient sent us an X-ray on WhatsApp — what do we do?

Health data is special-category data. It should move into an institutional, access-controlled environment, must not sit on personal devices, and the patient should be informed.

Is a single checkbox enough?

Rarely. The notice and the agreement serve different purposes, so they need separate controls, and the agreement has to name what it covers.

Does the agency see patient data?

No. Patient names, health records and imagery are neither requested nor processed; the work runs at anonymous flow and process level.

Are advertising platform forms a problem?

Platform forms collect data on the platform side, which raises additional notice and transfer questions. Treat them as a separate heading when mapping.

We already have a privacy notice — is this still needed?

Having the text is not enough; it must reflect the real data flow. The most common problem is that the channels named in the notice do not match the ones actually used.

How should we obtain image consent?

The consent text must be separate, narrow and purpose-bound; which image will be used on which channel and for how long must be written, and a withdrawal route defined.

Next step

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