COVID-19 PRIVACY STATEMENT
Personal data signifies any information concerning an identified or identifiable natural person (last name/first name, contact details, IP address, etc.).
1. Who is responsible for processing your personal data?
The controller of your personal data is the COCOM:
Commission communautaire commune de Bruxelles-Capitale (Joint Community Commission of Brussels-Capital)
71 Rue Belliard, post box 1,
If you have any questions regarding the processing of your personal data, please contact our data protection officer email@example.com.
2. Which personal data are processed?
The website brussels.testcovid.be processes all necessary data directly related to the possible infection of a patient within the framework of the COVID-19 pandemic and necessary to detect clusters of sources of infection. The database consists of the patient’s personal data (national registration number, name, date of birth, address, email address and/or mobile phone number), the necessary information about the reasons for a COVID test for the authorities and the laboratory which analyses the test (symptoms, stay abroad). The test results are shared with the patient and with healthcare professionals who have a therapeutic relationship with the patient. Positive test results are shared with the contact tracers.
The COCOM processes personal data to carry out the tasks assigned to it by law. The legal basis we invoke for this is the following:
- Consent (Article 6.1.a and Article 9.2.a GDPR) to process the test appointment
- Public interest or official authority (Article 6.1.e GDPR) to handle testing data
- Processing is necessary for the purposes of preventive medicine (Article 9.2.h GDPR).
The processing of personal data is done in compliance with data protection legislation (Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data).
3. For what purpose do we use your personal data?
The website brussels.testcovid.be aims to safely and efficiently survey the essential data of patients in the framework of the screening of patients without symptoms for COVID-19 (SARS-CoV2).
Patients can use this website to obtain an appointment at the test centres Pacheco, Mérode, Albert, Schaerbeek, Bruxelles-Midi, Bracops, Heysel or Molenbeek. Whether people can obtain an appointment or not is based on the applicable government guidelines. The organisation of the test centre itself has no responsibility in this regard. After completing the survey, the patient/user will receive an appointment or information on how to get access to a test.
The data from the survey are processed with the aim of providing scientifically substantiated advice, leading to a possibility to easily book an appointment at a test centre and, at the same time, generating a request for a lab test so that the test can be performed and analysed.
Before starting the survey, the participant is given the necessary information about the purpose of this website and what exactly he can expect from it.
Pseudonymised data are used for epidemiological and scientific research.
4. Storage period
The data from the survey which has to be completed in order to process the test appointment, will be stored for three weeks.
5. Sharing of personal data with third parties
The data entered on the website in order to obtain a test appointment are processed on behalf of the COCOM by Golazo NV and MediPortal BV, both processors of the COCOM.
The personal data entered by the patient when registering to book an appointment, are processed by Golazo. Mediportal processes the patient’s personal data and the medical data sent to the laboratory (batch number, COV number, type of test, etc.)
The result of the survey will be sent to the General Practitioner (GP) specified by the patient or to the GP who possesses his ‘dossier médical global’ (Global Medical File or GMF). The test results are made available to the patient via the website masante.belgique.be. The test results are also transmitted to the official authority within the framework of monitoring and contact tracing for COVID-19 in Belgium.
Given the processing of special categories of data, access to the data is restricted to healthcare professionals who have a therapeutic relationship with the patient and for whom the patient’s consent to the sharing of data has been obtained. Other healthcare providers do not have access to the patient’s data or data regarding contact that has taken place with a patient. All accesses are assigned a specific role and are also logged (date, time, who accessed the data, which data were changed). The data manager(s) has/have access to the data but is/are not allowed to consult it for unfounded reasons (i.e. only in the context of a therapeutic relationship, helpdesk function). This access is also logged.
Before the survey is completed and registered, the user is asked to give permission to use and share his data with the specified GP and/or the GP who possesses his GMF and the official authority.
Data are then processed in a pseudonymised way for general pandemic monitoring and scientific research purposes. Identity data are thus only shared with the patient’s own healthcare provider and the official authority.
6. Security measures
Both Golazo and Mediris take appropriate physical, administrative, organisational and technical security measures to protect your personal data against loss, unauthorised access, unauthorised use and unauthorised disclosure.
7. What are your rights?
- Right of information (GDPR: Art. 13, 14)
- Right of access (GDPR: Art. 15)
- Right to rectification (GDPR: Art. 16)
- Right to erasure (GDPR: Art. 17)
- Right to restriction of processing (GDPR: Art. 18)
- Right to data portability (GDPR: Art. 20)
- Right to object (GDPR: Art. 21)
- Right to withdraw consent
The right to erasure of data, right to data portability and right to object do not apply to the processing of personal data within the framework of a legal obligation or the processing necessary for the performance of tasks carried out in the public interest.
To exercise your rights, please send your request to our data protection officer: firstname.lastname@example.org. The request must be accompanied by a copy of your identity card.
The response time is one month. Exceptionally, this period may be extended (to a maximum of 3 months). However, in such a case we will inform you of the reason for this extension within a period of 1 month.
If you believe that the COCOM has not processed your personal data in accordance with the applicable regulations, you have the right to file a complaint with the Data Protection Authority:
Rue de la Presse 35
Email address: email@example.com
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