Date: 1/1/2018

Processing of information

In connection with our work‐up, diagnosing and treatment of you as a patient, Crete Fertility Centre collects and processes personal information about you. This Privacy Policy describes how the Crete Fertility Centre treats, uses and passes on your personal information. Types of information Crete Fertility Centre collects and processes the following types of personal information about you (to the extent that it is relevant for you) Common Categories of Personal Information • Name, address, e‐mail address, telephone number, social security number, gender, family relations and social relations, work relations and education. Special categories of personal data (“sensitive personal data”) • Health information (e.g. patient’s notes, test results, tests, x‐rays, scan results, etc.), sexual relations, racial or ethnic origin


We process your personal information for the following purposes:

  • Our examination, diagnostic and treatment of you.
  • Preparation of medical certificates.
  • Preparation of certificates for use by authorities, insurance companies etc.
  • Communication with or referral to other healthcare professionals, doctors, hospitals or hospital laboratories.
  • Medication, including issuing of prescriptions.
  • Reporting to clinical quality databases.
  • Reporting of laboratory tests to hospital laboratories.
  • Settlement Purposes.
  • Comply with our obligations under applicable legislation, including the EU Data Protection Act, Data Protection Act and other relevant health legislation, such as:
    • Documentation mandated by law.
    • Compliance with basic principles for processing personal data and legal basis for processing.
    • Implementation and maintenance of technical and organizational security measures, including but not limited to the prevention of unauthorized access to systems and information, to prevent the receipt or distribution of malicious code, the termination of overload attacks (denial of service attacks), and damage to computer systems and electronic communication systems.
    • Investigation of suspicion or knowledge of security breaches and reporting to individuals and authorities.
    • Handling queries and complaints from registrants and others.
    • Management of inspections and inquiries from authorities.
    • Handling disputes with registered and third parties.
    • Statistical studies and scientific research.


When we collect personal information directly from you, you provide your personal information voluntarily. You are not required to provide this personal information to us. The consequence of not giving us the personal information will be that we cannot fulfill the above objectives, meaning that we may be unable to examine, diagnose or treat you.


In some cases, we collect personal information about you from other healthcare professionals, such as hospitals, referring physician or from electronic journal systems. We process the received information in accordance with this Privacy Policy.

Disclosure of personal data

To the extent necessary for the specific examination, diagnosis or treatment of you, your personal information will be disclosed and shared with the following recipients:

  • Information is transmitted to other healthcare professionals if necessary for a current treatment course.
  • Information is transmitted to other authorities, clinical quality databases, the National Agency for Health Services in Greece, National Authority for Medical Assisted Reproduction in Greece, the Police, Social Authorities, Labor Market Insurance, to the extent that it is mandated according to applicable legislation.
  • As a patient, you have access to your own information (self‐access) if we have such access established.
  • Upon referral of patients, information is transmitted to the healthcare professionals to whom the referral has been sent.
  • When reporting laboratory tests, the tests are passed to the hospital laboratories.
  • When reporting information regarding patient treatment settlement, information is provided to the regional settlement offices.
  • When we issue prescriptions, information is transmitted to the country’s pharmacies and the Greek Medicines Agency via the prescription server.
  • When reporting to clinical quality databases.
  • For the transmission of discharge notes, information is transmitted to the referring physician and, in some cases, the referring hospital.
  • In other cases, information is conveyed to relatives or insurance companies.

Legal basis for processing and disclosure of personal data

The legal basis for collecting, processing and disclosing your personal information is:

  • For the purposes of ordinary patient treatment, personal data are collected, processed and transmitted pursuant to Article 6 (1) (c) and (d) of the Data Protection Regulation, while the sensitive personal data are collected, processed and transmitted pursuant to Article 9 (2) (c) and (h) of the General Data Protection Regulation).
  • In addition, we are obliged to treat a number of personal data about you in the ordinary patient treatment in accordance with the Greek Law for Medical Assisted Reproduction.
  • Health information for use for further treatment upon referral of patients is disclosed in accordance with the rules of the the Greek Law for Medical Assisted Reproduction.
  • Reporting of laboratory tests to hospital laboratories is done in accordance with the rules in the Greek’s National Authority for Medical Assisted Reproduction guidance.
  • Clinical patient data is passed to clinical quality databases in accordance with both the EU and Greek regulatory, and the notice on reporting of information to clinical quality databases, etc. Data may also be disclosed based on the specific consent from you as a patient.
  • Discharge notes, which is a brief summary of the patient’s history of illness and treatment, are sent to the referring physician and, in some cases, to the referring hospital.
  • Your personal information is disclosed only to insurance companies with your prior consent, cf. Article 6 (1)(a) and 9 (2)(a) of the Data Protection Regulation.
  • In the case of deceased patients, certain personal data may be disclosed to the deceased’s closest relatives, deceased general practitioner and the physician who had died in treatment.

Withdrawal of consent

If the processing of your personal data is based on your consent, you are entitled to revoke the consent. If you revoke your consent, it does not affect processing prior to revocation of consent, including a disclosure based on consent.

Using data processors

Your personal information may be processed and stored by our data processors, which keep them on behalf of and following instructions from us. Our data processors currently include:

  • OpenIT (“system house”, backup of data)
  • Gmail (secure mail) – Google’s Privacy Policy can be found here

Retention period

We keep personal information about you as long as we need to take care of the intended purposes. However, according to the registration order, we have an obligation to store these for a minimum of 10 years (certain types of data for 30 years) after the last entry to the notes. There may be cases where we need to store your personal information for a long time, for example, in connection with a complaint or compensation case, in which case information will be retained until the case is finalized.

Your rights

You have ‐ with the restrictions of the law ‐ certain rights, including the right to ask for: access personal data, change incorrect information, delete information, have limited information, data portability, object to the treatment of personal data, including automated, individual decision making (“profiling”).


If you have questions regarding the processing of your personal information or the use of your rights, please feel free to contact us.

Data Controllers

CRETE FERILITY CENTRE, MEDICAL LTD COMPANY Licensed Medical Assisted Reproduction Unit & Cryopreservation Bank (2962 B/29-08-2017) Address: 56 Arch. Makariou & Sofokli Venizelou, 71202, Heraklion, Crete, Greece, Tel: +30 2810 245253 Certified with:

  • BS EN 15224:2016 (26/02/2018)
  • ISO 9001:2008 (19/05/2016)

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