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Processing of personal data

Who is responsible for the processing of your personal data?

The data controller is CLÍNICA UNIVERSIDAD DE NAVARRA, with NIF R3168001J and registered office at Avenida Pio XII, 36, 31008, Pamplona, (hereinafter, "CUN").

You can contact the person in charge through the following e-mail addresses:

CUN has formally appointed a Delegate for Personal Data Protection and has also enabled the following communication channel: dpocun@unav.es

How do we obtain your personal data?

In order to answer this question, a distinction must be made between the sources from which your personal data originate and the type of personal data processed by CUN:

a.- Sources from which the personal data originate.

  • Provided by the patient in the legal, contractual, healthcare or any other type of relationship that he/she enters into with Cun.
  • The management, maintenance and development of the relationship between CUN and the patient.
  • Insurance companies.
  • Public bodies and administrations.

b.- Types of personal data.

  • Data on personal characteristics and social circumstances.
  • Clinical and health data contained in your medical history, obtained during the development of the relationship between CUN and the patient.
  • Economic, financial and insurance data necessary for billing your medical care.

In the event that the patient provides the identification and contact information of persons related to him/her for family or factual reasons so that CUN can keep them informed about his/her health condition, the patient is obliged to inform them about the treatment that CUN will carry out with their personal information..

For what purposes do we process your personal data?

CUN processes your personal data to achieve the purposes detailed below, along with the applicable legitimate bases.

Purpose of processing Legitimate basis

Management, maintenance and development of the legal, contractual and/or healthcare relationship between CUN and the patient, which may include:

  1. Health care provided to the patient.
  2. Medical tests performed on the patient.
  3. Clinical diagnoses.
  4. Any other matter required in the development of the healthcare practice.
 The formalization, development, execution and maintenance of the healthcare, legal and/or contractual relationship formalized between the patient and CUN, as well as preventive or occupational medicine, evaluation of the worker's capacity to work, medical diagnosis, provision of healthcare or social assistance or treatment, or management of healthcare and social assistance systems and services.
Collection and billing management of medical assistance and interventions performed. The formalization, development, execution and maintenance of the healthcare, legal and/or contractual relationship formalized between the patient and CUN.
Quality management and continuous improvement of the service through data analysis and artificial intelligence tools. In order to guarantee the continuous improvement of the business model and the correct optimization of resources, CUN may analyze certain information that includes personal data in order to detect and remedy any deficiencies or aspects of improvement in the delivery of the service that may be detected (for example, optimization of space in the facilities or increased efficiency of the personnel).    

CUN's legitimate interest in processing data that is not specially protected lies in quality management and continuous improvement of service, optimizing available resources and providing customers with better attention to their needs.

You may object at any time to the processing of your data for this purpose by using the channels provided by CUN, as detailed in the section What are your rights regarding our processing of your data?

Use of medical data for research purposes carried out at CUN, if you have given your consent. The processing of medical data for research purposes will always be carried out in accordance with current legislation.

In addition, we inform you that such processing will be carried out with coded and/or pseudo-anonymized data, in strict compliance with the security measures applicable to the storage and custody of the data and, in any case, following the opinion of the Ethics Committee of CLÍNICA
UNIVERSIDAD DE NAVARRA.

Your consent granted by ticking the box provided for this purpose.

You may withdraw your consent at any time by using the channels provided by CUN, as detailed in the section What are your rights in relation to our processing of your data?
CUN will send you information by mail, telephone, or electronic means concerning CUN, the University of Navarra, or CIMA (Center for Applied Medical Research). This information will refer to projects, activities or research studies carried out by these entities, advances and new products, services and techniques in the health care and research fields, as well as products and services provided by CUN, the University of Navarra or CIMA. It will also include information on CUN's collaborating entities in the hospitality and commerce sectors. All of the above, exclusively if you have given your consent.

Your consent is granted by checking the box provided for this purpose.

You may withdraw your consent at any time by using the channels provided by CUN, as detailed in the section What are your rights regarding our processing of your data?
Use of data to inform patients by CUN of clinical research projects developed by CLÍNICA UNIVERSIDAD DE NAVARRA, either individually or in collaboration with other scientific research entities, and to request their participation in these projects, only if they have given their consent.    

Your consent is given by ticking the box provided for this purpose.

You may withdraw your consent at any time by using the channels provided by CUN, as detailed in the section What are your rights in relation to the processing of your data by us?
Access to personal data by CLÍNICA UNIVERSIDAD DE NAVARRA students for teaching purposes only if they have given their consent.    

Your consent given by ticking the box provided for this purpose.

You may withdraw your consent at any time by using the channels provided by CUN, as detailed in the section What are your rights in relation to the processing of your data?

To which recipients will your personal data be communicated?

The personal data processed by CUN to achieve the purposes detailed above may be communicated to the following recipients depending on the legitimate basis for the communication.

By virtue of the above, the following data communications are intended to guarantee the correct development of the contractual relationship, as well as to comply with legal obligations that require the aforementioned communications to be made:

  • Public Bodies and Administrations for compliance with the legal obligations to which CUN is subject.
  • Financial institutions for the management of collections and payments.
  • Entities supplying health material and products, as well as pharmaceutical companies.
  • Insurance companies for the maintenance of the health and financial relationship.

How long do we keep your data?

Personal data will be kept for the duration of the healthcare, legal and / or contractual relationship and, thereafter, provided that you have not exercised your right of deletion, will be retained taking into account the legal deadlines that apply in each specific case, taking into account the type of data and the purpose of processing.

The data and documentation that serve as proof of the healthcare and/or legal relationship that the patient has established with CLÍNICA UNIVERSIDAD DE NAVARRA will be kept during the conservation periods imposed by the applicable regulations, as well as during the prescription periods for civil, criminal, administrative or any other type of action that could be derived from the relationship established.

You can request more information about CLÍNICA UNIVERSIDAD DE NAVARRA's personal data retention dpocun@unav.es

What are your rights in relation to our processing of your data?

CUN informs you that you have the right to access your personal data and obtain confirmation of how such data is being processed. You also have the right to request the rectification of inaccurate data or, where appropriate, to request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected by CUN.

In certain circumstances, you may request the limitation of the processing of your data, in which case CUN will only keep them for the exercise or defense of possible claims.

Likewise, also in certain circumstances, you may object to the processing of your personal data for the purpose informed by CUN. In this case, CUN will cease to process your personal data, except for legitimate reasons, or for the exercise or defense of possible claims.

Finally, you may request the right to portability and obtain for yourself or for another service provider certain information derived from the contractual relationship formalized with the Entity.

Likewise, we remind you that you may object at any time to the processing of your data for advertising or promotional purposes.

You may exercise these rights by writing to "CLÍNICA UNIVERSIDAD DE NAVARRA" and sending it to one of the following addresses:

  • If you are a patient in Pamplona, to the following address: Avenida Pio XII, 36, 31008, Pamplona. Patient Attention Service.
  • If you are a patient from Madrid, to the following address: Calle Marquesado de Santa Marta, 1, 28027 Madrid. Security and Data Protection Unit.

In both cases, the letter must include the reference "Data Protection" and provide your name, surname(s), a postal address or e-mail address for notification purposes and the right you wish to exercise.

CUN informs you that you can find models of documents through which you can exercise your data protection rights on the website of the Spanish Data Protection Agency (www.agpd.es)

CUN will provide you with the requested information within a maximum period of one month from receipt of the request. This period may be extended for a further two months if necessary, taking into account the complexity and number of requests.

You may withdraw your consent at any time, in the event that consent has been given for a specific purpose, without affecting the lawfulness of the processing based on the consent prior to its withdrawal.

You may lodge a complaint with the competent data protection supervisory authority. However, in the first instance, you may file a complaint with the Data Protection Delegate, at the e-mail address dpocun@unav.es, who will resolve the complaint within a maximum period of two months.

We inform you that, as a signatory, you accept that the signature of the document is produced in electronic form by means of your digital signature. If you use the digital signature system, CUN will process the biometric data associated with said signature solely for the purpose of maintaining the traceability of the receipt and acceptance of the documentation. If you do not wish to provide such data, you may sign the document on paper.