Protection of Personal Data
Disclosure notice on how messages, images and health information sent through the WhatsApp line or by email are handled.
This is a disclosure notice prepared under Article 10 of Turkish Personal Data Protection Law no. 6698. It is published so that anyone sending messages, images or health information through the WhatsApp line or by email is informed beforehand about how that information is handled.
You are expected to read it before sending anything. If, having read it, you would rather not share images, you can attend the hospital for a face-to-face examination without sending anything at all.
Data controller
| Name and title | Op. Dr. Oğuzhan Durmuş, Specialist in Plastic, Reconstructive and Aesthetic Surgery |
| Address | Erzincan Binali Yildirim University Mengucek Gazi Training and Research Hospital, Merkez / ERZINCAN |
The data controller is not WhatsApp or the company operating it. The controller is the physician named above, as the person who decides the purpose and means of the processing. WhatsApp and the email service are the means by which the message travels.
What is processed
- The images you send
- The health information, complaint and any previous treatment you describe
- The telephone number the message comes from and the name shown on your WhatsApp profile
- If you write by email, your email address and the name you give in the message
Images and health information are special category personal data under Article 6 of the Law and are subject to separate protection.
Purpose
For messages containing health information there is a single purpose: to give guidance, based on the images and information you send, before you travel to the hospital, on whether the matter is suitable for a face-to-face examination.
What this guidance does not replace
An assessment made from an image is not a medical decision or a piece of advice, it is preliminary information only. No diagnosis is made, no treatment plan is drawn up, and no medication or procedure is recommended.
Medical assessment and advice are given after a face-to-face examination at Mengucek Gazi Training and Research Hospital, following formal patient registration.
Legal basis
Under Article 6(3) of the Law, health data may be processed without explicit consent by persons under a duty of confidentiality, for the purposes of medical diagnosis, treatment and care. A physician's duty of confidentiality arises from legislation and is continuing.
The processing rests on that provision. Sending an image is not by itself treated as a declaration of consent; the basis for processing is the statutory provision above.
Transfer of data
The images and information you send are not shared with third parties and are seen only by the physician named above. They are not used for promotion, social media, teaching, publication or any similar purpose. This limit holds even where permission is given.
One point should nonetheless be clearly understood. WhatsApp is operated by a company established abroad. By the nature of the service, messages travel through that company's systems outside Turkey. This amounts to a transfer abroad within the meaning of Article 9 of the Law and lies outside the physician's control.
WhatsApp states that it encrypts messages end to end. That statement concerns the security of transmission; it does not mean the data avoids passing through systems abroad.
The email address (iletisim@droguzhandurmus.com) is hosted on a service operated by Google. Messages and attachments sent by email are stored on that company's systems outside Turkey; this too is a transfer abroad within the meaning of Article 9 of the Law.
If you would rather your images were not sent through an application or service based abroad, it is enough not to send them and to attend a face-to-face examination directly.
How data is collected
Data is collected only to the extent that you send it, through the WhatsApp line or by email, by electronic means. The contact form on this site does not send your message to the site or store it; it only opens your own app with the text filled in. Voice calls are not accepted on the WhatsApp line.
Retention and deletion
Images received on WhatsApp are not taken out of the application. They are not transferred to a computer, to cloud storage or to any other medium, are not printed, and are not placed in the patient file.
Once the assessment is complete the images are deleted. If you attend for a face-to-face examination, the record of that examination is kept in the hospital's own system, independently of this WhatsApp line and of the email correspondence.
Images and health information received by email are likewise deleted from the mailbox once the assessment is complete.
Measures taken
- The images are seen only by the physician acting as data controller
- Automatic saving of media to the device gallery is switched off
- The line is used for written messages only; incoming calls are disabled
- The correspondence and the images are deleted once the assessment is complete, on WhatsApp and by email alike
Your rights
Under Article 11 of the Law you have the right to learn whether your personal data is being processed and to request information where it has been. The same article gives you the right to learn the purpose of processing and whether the data is used in line with that purpose, to request correction where it is incomplete or inaccurate, and to request erasure or destruction. That article also gives you the right to claim compensation where you suffer loss because of unlawful processing.
Making a request
To exercise these rights you may apply in writing to the address above, or use the editor contact address given on the site's imprint page. Your request will be concluded within 30 days at the latest.