Data controller
A data controller is the person or organisation that decides the purposes and means of processing personal data and is responsible for setting up and running the filing system that holds it.
Who is the data controller in a clinic?
The clinic decides why it collects patients' data, how long it keeps it and who it shares it with, so the clinic is the data controller. In a private practice that is often the doctor personally; in a clinic run as a company, it is the company. Informing people, obtaining explicit consent where needed, keeping data secure, answering people's requests and registering with VERBİS where required are all the controller's duties.
Under the Board's decision 2020/71, what counts is who decides why and how data is processed: which data is collected, from whom and how, how long it is kept and who it is shared with. The same company can be a controller for one activity and a processor for another, so the role is assessed activity by activity. The controller can give the privacy notice itself or authorise someone else to do it.
In Klinikbook
For patient data in Klinikbook, the controller is the clinic or agency that opened the workspace, and SetteTech, which runs Klinikbook, is its processor. For its own website, user accounts and subscription invoices, SetteTech is the controller. The compliance centre gathers the texts, requests and records you need as a controller in one place.
Sources
- Law No. 6698 on the Protection of Personal Data (Turkish text) — Mevzuat Bilgi Sistemi, Official Gazette, 7 April 2016
- Decision 2020/71: telling a data controller from a data processor (Turkish) — Personal Data Protection Authority (KVKK), 30 January 2020
Related reading
- GlossaryData processorA data processor is a person or organisation that processes personal data on behalf of a data controller, under its authority, such as the cloud software, hosting or accounting provider a clinic uses.
- GlossaryData processing agreementA data processing agreement (DPA) is the contract between a data controller and a provider processing personal data on its behalf, setting out the subject of processing, instructions, security and each side's responsibilities.
- GlossaryVERBİSVERBİS is the Data Controllers' Registry Information System that Türkiye's Personal Data Protection Authority keeps open to the public under Article 16 of KVKK. Controllers that must register record their processing there.
- GuidesKVKK for clinics: privacy notices and explicit consentUnder Türkiye's data protection law (KVKK), a clinic is the data controller for its patients' data. It must give a privacy notice whenever it collects data, and may process health data only on one of the grounds in Article 6. Where it relies on explicit consent, the consent text is kept separate from the notice.
Try Klinikbook with your own team
Every feature is open for 30 days, and no card is needed to start.