Privacy Policy
1. The purpose of the policy
Progardia Healthcare ApS (“Progardia”) processes personal information about you in a number of situations. This happens, for example, when Progardia establishes a contact with you as a patient, and in connection with the provision of healthcare services, including examination and diagnostics, or if you otherwise come into contact with Progardia, e.g. as a supplier or partner, if you apply for a job at Progardia, or visit Progardia's website.
As a rule, Progardia must ensure that you are informed if Progardia processes your personal data. In some cases, however, Progardia is prevented from complying with this disclosure obligation. This is especially true in cases where Progardia is subject to professional secrecy or other interests are crucial against informing you. This privacy policy contains information about Progardia's processing of personal data, which you can read more about below.
2. Data controller
The legal entity that is responsible for the processing of personal data at Progardia is:
Progardia Healthcare ApS
CVR-nr.: 41480580
Teglgårdsparken 118
5500 Middelfart
Progardia can be contacted regarding its processing of personal data at:
Phone: +45 70 60 11 60
E-mail: info@progardia.dk
3. Progardia's processing of personal data
You can read more about how Progardia processes personal information below:
| Patient administration | |
|---|---|
| Purpose | The purpose is to handle patient administration, including communication, planning and invoicing. |
| Registered | The patient |
| Categories of personal information | General personal information, including information about name, address, telephone number and e-mail address. Furthermore, Progardia may process special categories of personal information, including information about trade union affiliation, where Progardia provides healthcare services to patients as part of the patient's membership of such association. |
| Legal basis for treatment | The processing is necessary for Progardia to fulfil the agreement with the patient or to implement measures at the patient's request prior to the conclusion of the agreement, cf. Article 6 (1) of the Data Protection Regulation. 1, letter b. The processing is also necessary for Progardia to comply with a legal obligation, including section 10 of the Accounting Act, to which Progardia is subject, cf. Article 6 (1) of the Data Protection Regulation. 1, letter c. Furthermore, the processing is necessary for Progardia to pursue its legitimate interest in managing the patient relationship, including communicating, planning and invoicing, in accordance with Article 6 (1) of the Data Protection Regulation. 1, letter f. Note that the data subject may at any time object to this, cf. Art. 21, para. 4. |
| Source | The patient |
| Period of treatment | The information is stored for a minimum of 10 years after the last entry in the record. If a complaint, supervision or compensation case is pending, where the information is relevant to the case, the information is stored for as long as the case is pending after the expiry of the 10 years. |
| Categories of recipients | Where it has been agreed that Progardia's healthcare services are to be paid for by the patient's organization, employer or the public sector, Progardia passes on personal information that appears on the invoice to the organization, employer or region in question. Progardia also passes on the personal information to the auditor and other professional advisers, e.g. for the auditor to perform the audit, or in connection with the receipt of advice. In addition, Progardia uses external suppliers, including IT suppliers and external accountants, who are given personal information in connection with their assistance to Progardia. Progardia has entered into data processor agreements with external suppliers that process personal data on behalf of Progardia. Progardia does not transfer information to third countries or international organizations. |
| Examination and diagnosis | |
|---|---|
| Purpose | The purpose is examination and diagnosis, including submission of laboratory samples to hospital laboratories. |
| Registered | The patient |
| Categories of personal information | General personal information that appears in the patient record, including information about name and address, height and weight, and CPR number. Special categories of personal information appearing in the patient record, including health information, including in the form of diagnostic imaging material. |
| Legal basis for treatment | Processing of general personal data is necessary for the sake of Progardia's compliance with the agreement with the patient, or for the sake of implementing measures taken at the patient's request prior to the conclusion of the agreement, in accordance with Article 6 (1) of the Data Protection Regulation. 1, letter b. Processing of general and special categories of personal data is also necessary to comply with a legal obligation, including the record keeping obligation, which is incumbent on Progardia pursuant to Executive Order 2019-07-08 no. 731 on authorization of healthcare professionals and on healthcare professional chapter 6, as well as Executive Order 2021 -06-08 no. 1225 on patient health records of authorized healthcare professionals (record keeping, storage, transfer, transfer, etc.), including in particular sections 5, 29 and 35, cf. Article 6 (1) of the Data Protection Regulation. 1, letter c, and Article 9, para. 2, letter f. Furthermore, the processing of special categories of personal data, including health data, is necessary for the prevention of disease control, medical diagnosis, and the management of medical and health services, in accordance with Article 9 (1) of the Data Protection Regulation. 2, letter h, cf. the Data Protection Act § 7, para. 3. Processing of CPR no. consequences of the legislation, including Executive Order 2021-06-08 no. 1225 on authorized healthcare professionals' patient records (record keeping, storage, disclosure, transfer, etc.), including in particular sections 5, 29 and 35, cf. Article 87 of the Data Protection Ordinance, cf. section 11 of the Data Protection Act. , PCS. 2, Nos. 1 and 3. Disclosure of general and special categories of personal data takes place on the basis of the patient's consent pursuant to Chapter 9 of the Health Act, cf. Article 6 (1) of the Data Protection Regulation. Article 9 (1) (a). Furthermore, personal data is passed on in order to comply with a legal obligation, including the Danish Agency for Patient Safety or the medical officer to which Progardia is subject, or to determine, assert or defend a legal claim, cf. Article 6 (1) of the Data Protection Regulation. Article 9 (1) (c) and Article 9 (1) 2, letter f. Disclosure of CPR no. is necessary to ensure an unambiguous identification of the patient or is required by a public authority, cf. Article 87 of the Data Protection Regulation, cf. section 11 (1) of the Data Protection Act. 2, No. 3. |
| Source | The patient himself, as well as from hospitals, doctors / specialists and private hospitals. |
| Period of treatment | The information is stored for a minimum of 10 years after the last entry in the record. If a complaint, supervision or compensation case is pending, where the information is relevant to the case, the information is stored for as long as the case is pending after the expiry of the 10 years. |
| Categories of recipients | Progardia passes on the personal information in the patient record to general practitioners or specialists, public hospitals and private hospitals with the patient's consent. In addition, Progardia passes on personal information when reporting laboratory samples to the hospital laboratories. When issuing prescriptions, information is passed on to the country's pharmacies and the Danish Medicines Agency via the prescription server. If the region pays for the health services, Progardia will pass on the personal information in the patient record to the referring hospital department, as well as to the region in question in connection with invoicing to the region. In addition, Progardia uses external suppliers, including IT suppliers, who are given personal information in connection with their assistance to Progardia. Progardia has entered into data processor agreements with external suppliers that process personal data on behalf of Progardia. Progardia does not transfer information to third countries or international organizations. |
| Marketing initiatives | |
|---|---|
| Purpose | The purpose is to market Progardia's business and services. |
| Registered | The contacted via phone / mail. |
| Categories of personal information | General personal information including name, title, email address, telephone number and organization. |
| Legal basis for treatment | If we have previously had contact with a relationship in one way or another, we consider that we have a legitimate interest in processing its personal data so that we can maintain our relationship and market our services, as well as ensure that our inquiries to our relationship is as relevant as possible, cf. Article 6 (1) of the Data Protection Regulation. 1, letter f. Note that the data subject may at any time object to this, cf. Art. 21, para. 4. |
| Source | The relationship itself or from publicly available sources, e.g. LinkedIn, Facebook or the relationship organization's website. |
| Period of treatment | The information is deleted when the relationship itself refuses us to maintain contact. |
| Categories of recipients | –––– |
| Visitors to progardia.dk | |
|---|---|
| Purpose | The purpose is administration of visitors to progardia.dk, including maintain functionality, statistics and marketing. |
| Registered | The visitor to progardia.dk. |
| Categories of personal information | General personal information, including IP address and date. |
| Legal basis for treatment | Progardia pursues its legitimate interest in storing the necessary cookies, cf. Article 6 (1) of the Data Protection Regulation. 1, letter f. Note that the data subject may at any time object to this, cf. Art. 21, para. 4. Progardia stores other cookies with the visitor's consent, cf. Article 6 (1) of the Data Protection Regulation. 1, letter a. You can read more about Progardia's use of cookies in Progardias Cookie Policy. |
| Source | The visitor. |
| Period of treatment | Information about the duration of the individual cookie is detailed in Progardias Cookie Policy. |
| Categories of recipients |
In certain cases, Progardia passes on personal information to professional advisers in connection with the receipt of advice. In addition, Progardia uses external suppliers, including IT suppliers, who are given personal information in connection with their assistance to Progardia. Progardia has entered into data processor agreements with external suppliers that process personal data on behalf of Progardia. |
| Recruitment | |
|---|---|
| Purpose | The purpose is recruitment, including processing and assessing an applicant in relation to a current or future position at Progardia. |
| Registered | The applicant. |
| Categories of personal information |
General personal information, including name, address, telephone number and e-mail address, educational background, work experience and other personal information provided by the applicant, as well as references. Information on criminal offenses, including criminal record, on the applicant being offered a position. In certain cases, Progardia processes special categories of personal data, including diseases that will currently have a significant impact on the applicant's ability to perform the position in question. |
| Legal basis for treatment |
The processing of ordinary personal data is necessary for Progardia to pursue a legitimate interest in being able to recruit an applicant for a position with Progardia, in accordance with Article 6 (1) of the Data Protection Regulation. 1, letter f. Note that the data subject may at any time object to this, cf. Art. 21, para. 4. Progardia processes personal data obtained by reference if the applicant has given his consent, in accordance with Article 6 (1) of the Data Protection Regulation. 1, letter a. Progardia also processes personal data which are clearly published by the applicant himself, in accordance with Article 6 (1) of the Data Protection Regulation. Article 9 (1) (f) and Article 9 (1) 2, letter e. In this context, Progardia pursues a legitimate interest in being able to recruit applicants for positions at Progardia. Please note that the data subject may at any time object to this, cf. the nature of the Data Protection Regulation. 21, para. 4. Progardia processes information on criminal records if it is necessary to pursue a legitimate interest in ensuring that the applicant can handle the position at Progardia that is to be filled, cf. Article 10 of the Data Protection Regulation, cf. section 8 (1) of the Data Protection Act. 3. The processing of special categories of personal data is necessary in order to comply with Progardia's or the applicant's employment law obligations and specific rights, including the Act on the Use of Health Data, etc. in the labor market § 2, cf. the Data Protection Act § 12, para. 1. |
| Source | The applicant and at evt. references (if the applicant has given his consent) as well as information that is otherwise publicly available. |
| Period of treatment | Information about an applicant who is not offered a position is deleted after 3 months, calculated from the time when the applicant has received rejection of his application, unless the applicant has given consent to a longer retention period, or special circumstances require a longer retention. Information about applicants who are offered a position at Progardia is transferred to the applicant's personnel file. |
| Categories of recipients |
In certain cases, Progardia passes on personal information to its professional advisers in connection with the receipt of advice. In addition, Progardia uses external suppliers, including IT suppliers, who are given personal information in connection with their assistance to Progardia. Progardia has entered into data processor agreements with external suppliers that process personal data on behalf of Progardia. Progardia does not transfer information to third countries or international organizations. |
| Supplier Administration | |
|---|---|
| Purpose | The purpose is to handle the administration of supplier and collaboration relationships. |
| Registered | The supplier or partner, as well as employees at these. |
| Categories of personal information | General personal information, including name, title, address, telephone number and e-mail address. For employees of the supplier or partner, Progardia processes name, title, e-mail address and telephone number. |
| Legal basis for treatment |
The processing is necessary in order to fulfill the agreement with Progardia's supplier or business partner or to implement measures at their request prior to the conclusion of the agreement, in accordance with Article 6 (1) of the Data Protection Regulation. 1, letter b. The processing is also necessary for Progardia to comply with a legal obligation, including requirements in section 10 of the Accounting Act, to which Progardia is subject, cf. Article 6 (1) of the Data Protection Regulation. 1, letter c. Furthermore, the processing is necessary for Progardia to pursue its legitimate interest in managing the supplier or cooperation relationship and fulfill the agreement with its supplier or partner, cf. Article 6 (1) of the Data Protection Regulation. 1, letter f. Note that the data subject may at any time object to this, cf. Art. 21, para. 4. |
| Source | The supplier or partner, as well as employees at these. |
| Period of treatment | The information is deleted after 6 years, calculated from the end of the calendar year in which the supplier or cooperation relationship ends, unless special circumstances require a shorter or longer storage period. |
| Categories of recipients |
Progardia only passes on personal information to accountants and other professional advisers, e.g. for the auditor to perform the audit, or for Progardia to receive advice. In addition, Progardia uses external suppliers, including IT suppliers and external accountants, who are given personal information in connection with their assistance to Progardia. Progardia has entered into data processor agreements with external suppliers that process personal data on behalf of Progardia. Progardia does not transfer information to third countries or international organizations. |
4. Treatment security
Progardia is committed to protecting the confidentiality, integrity and availability of Progardia's patient and other relationships information, including personal information. Progardia gives high priority to patient confidentiality and information security, and Progardia is strongly committed to ensuring continuous protection of information. Progardia has implemented security measures to ensure the protection of patient information, personal information and other confidential information. Progardia regularly conducts internal follow-ups to ensure adequate security and compliance with Progardia's policies.
5. Your rights as registered
As registered, you have a number of fundamental rights. However, these rights may be restricted, e.g. if the disclosure of information that you were otherwise entitled to receive would violate the rights of other persons or be in breach of Progardia's confidentiality.
- Withdraw consent
To the extent that Progardia's processing of your personal data is based on your consent, you may withdraw your consent at any time. However, the revocation does not affect the legality of the treatment that Progardia has carried out prior to the revocation. To withdraw your consent to Progardia's processing of your personal data, please contact us. - Right to insight
In principle, you have the right to be informed whether Progardia processes personal data about you, and if so, which personal data and how Progardia processes them, as well as to receive a copy thereof. - Right to rectification
You have the right to have incorrect or incomplete personal information corrected. If the information is passed on to others, we ensure that the recipients are informed of the correction, if possible and legally. - Right to delete.
You may have the right to have the personal data that Progardia processes about you deleted. If the information has been passed on to others, we ensure that the recipients are informed of a possible deletion, if possible and lawful.
- Right to limitation of treatment
You may have the right to have the processing of your personal data restricted, so that the information is simply stored by Progardia. If the information has been passed on to others, we ensure that the recipients are informed of a possible restriction if possible and lawful. - Right to transmit personal data ("data portability")
In certain cases, you have the right to receive the personal information about you that you have given us in a structured, commonly used and machine-readable format and to have the information transferred to another data controller. - Right to object to Progardia's treatment
In certain cases, you have the right to object to Progardia's processing of your information.
6. Changes to this Privacy Policy
Transparency is an ongoing responsibility and Progardia therefore updates this privacy policy continuously.
The privacy policy was last updated on June 23, 2021.
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Contact and complaint
If you wish to complain about Progardia's processing of your personal data, please send an email with your complaint to info@progardia.dk. Progardia will process the complaint and return as soon as possible.
You also have the right to complain to the Danish Data Protection Agency:
Datatilsynet
Borgergade 28, 5.
1300 København K.
Phone: 33193200
E-mail: dt@datatilsynet.dk
For further information on how to complain to the Danish Data Protection Agency, please refer to the Danish Data Protection Agency's website: https://www.datatilsynet.dk/english.