TURKISH HEPATO PANCREATO BILIARY SURGERY ASSOCIATION CLARIFICATION TEXT ON THE PROTECTION AND PROCESSING OF PERSONAL DATA

As Turkish Hepato Pancreato Biliary Surgery Association (‘HPB Association’), we show the utmost care and sensitivity regarding your personal information and your right to privacy. For this reason, we would like to inform and enlighten you about our personal data processing activities in accordance with Article 10 of the Law No. 6698 on the Protection of Personal Data.

This Clarification Text specifies how HPB Association collects your personal data, why it collects it, with whom it can share it and details the rights of personal data owners.

1.           DATA RESPONSIBLE

Pursuant to the Law No. 6698 on the Protection of Personal Data, HPB Association, as the data controller, will be able to process, record, store, store, classify,, and disclose/transfer your personal data to third parties within the scope of the purposes described below; in accordance with the law and honesty rules and in cases permitted by the legislation and / or ed to the purpose for which they are processed.

2.           PURPOSE OF PROCESSING PERSONAL DATA

HPB Association, as the Data Processor, collects personal information in accordance with its activities, especially the Regulation on the Safety of Medicines and Good Pharmacovigilance Practices Guidelines published by T. C. Ministry of Health, Turkey Pharmaceuticals and Medical Devices Agency. The personal data received are stored securely in physical or electronic media in accordance with the KVKK and the periods specified in other relevant laws.

In order to carry out the activities of the human resources department, including compliance with the provisions of the Labor Law No. 4857, management of payroll processes, fulfillment of obligations arising employment contracts and legislation, ensuring communication in business activities and emergencies, conducting inventory and training activities, managing contract processes, receiving and evaluating proposals for improving business processes, and conducting cargo and logistics activities and providing information to authorized individuals, institutions, and organizations,

Personal data belonging to candidate employees who apply for a job; in order to carry out job application processes and to ensure communication,

Ensure communication, to carry out communication activities with our customers and customer candidates,

To be able to fulfill the data storage activities of its service customers as a Data Processor, ,

To carry out presentations and trainings specific to the health sector,

In order to complete the records of the Application Users served and to carry out the accounting processes related to this activity,

To ensure the security of Cargo customers and visitors, and to ensure the uninterrupted continuity of logistics activities,

In order to ensure the continuity of product, support and services within the scope of the contract with our suppliers and to fulfill the terms of the contract and to ensure communication,

Personal data are collected and processed by HPB Association.

The personal data received are protected by HPB Association by taking administrative and technical measures in accordance with the obligations stipulated in all relevant legislation, especially KVKK.

Personal data belonging to personnel who have previously worked, continue to work and work as interns; job application processes and working processes, SSI notifications, HPB Association physical security measures are taken to fulfill.

The relevant person who is the owner of personal data can access detailed information about the purposes of processing personal data the Policy on Processing and Protection of Personal Data declared on the website Privacy Policy.

3.           DELETION OF PERSONAL DATA

The relevant person who is the owner of personal data can access detailed information on the deletion of personal data the Personal Data Storage and Destruction Policy declared on the website Privacy Policy.

4.           SHARING YOUR PERSONAL DATA

Personal data of employees, employee candidates, cargo customers, potential product or service recipients, product or service recipients, application users, supplier employees, supplier officials, visitors, relevant persons of customers and parents/guardians/representatives may be shared with relevant Public Institutions and Organizations, Customers, Suppliers, Financial Advisors and Contracted Law Offices in accordance with the basic principles stipulated in the KVKK and within the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVKK, provided that public interest is observed. In addition, personnel information may be shared with banks for the fulfillment of related activities. Personal data obtained during trainings specific to the health sector can be shared with everyone via social media. Some of your personal data may be shared with our domestic and foreign customers in order to fulfill the requirements of the Pharmacovigilance Regulation.

5.           PERSONAL DATA RECEIVED

The categories of personal data received are set out below;

Employees; Personal, identity, communication, professional supervision, transaction security (log records), criminal conviction information, religious information (Identity Photocopy), audio-visual record, certificate of no debt, health information,

Employee Candidates; Identity, Communication, personal, professional experience

Cargo Customer; Identity, contact

Potential Product or Service Buyer; Identity, contact

Person Receiving Product or Service; Identity, Contact, Customer Transaction

Supplier Employee; Communication, visual and audio recordings

Supplier Official; Identity, communication, customer transaction, audio and visual records

Parent / Guardian / Representative; Identity,

Visitor; Identification

Application User; Identity, Contact, professional experience, transaction security (ip address), customer transaction

Customer's Relevant Person; Personal, identity, communication, professional experience, customer transaction, transaction security, biometric data, criminal conviction and security measures, sexual life, association membership, religious information, finance, physical space security, genetic data, audio-visual records, legal transaction, race and ethnicity, clothing, location, marketing, risk management, health information, union membership, political opinion information, foundation membership

6.           METHODS AND LEGAL GROUNDS FOR COLLECTING YOUR PERSONAL DATA

Your personal data may be processed and transferred by obtaining explicit consent in the light of the principles stipulated in Article 4(2) of the KVKK or in the presence of the situations stipulated in Articles 5(2) and 6(3), without obtaining explicit consent.

Your personal data is processed within the scope of Good Pharmacovigilance Practice Guide (GVP), Good Clinical Practice Guide (GCP), Medicines Safety Regulation and other laws to which HPB Association is obliged.

Contracts are signed or explicit consents are obtained in order to obtain your personal data other than these that need to be processed.

Personal data belonging to former and continuing employees are obtained through online job application sites.

7.           STORAGE OF PERSONAL DATA

Personal data are stored in accordance with the periods determined by the relevant laws and regulations. Data retention periods are determined according to the time periods stipulated by laws and contracts. Depending on the period stipulated by the KVKK, checks are carried out every six months. Personal data whose retention period has expired are destroyed under appropriate conditions.

Details regarding retention are specified in the Personal Data Retention and Destruction Policy document.

8.           RIGHTS OF THE DATA SUBJECT WHOSE PERSONAL DATA IS PROCESSED

You can use the following rights regarding the processing of your personal data with a request to HPB Association. Requests submitted within this scope will be finalized free of charge by HPB Association within thirty days at the latest. However, if a fee is stipulated by the Personal Data Protection Board, HPB Association may charge the fee in the determined tariff. In this context, as the personal data owner;

•            Learn whether your personal data is being processed,

•            Request information if your personal data has been processed,

•            Learn the purpose of processing your personal data and whether they are used in accordance with their purpose,

•            To know the third parties to whom your personal data is transferred domestically or abroad,

•            To request correction of your personal data in case of incomplete or incorrect processing,

•            Request deletion or destruction of your personal data,

•            In case your personal data is corrected, d or destroyed, to request that these transactions be notified to third parties to whom your personal data has been transferred,

•            Object to the occurrence of a result against you by analyzing your processed data exclusively through automated systems,

•            In case you suffer damage due to unlawful processing of your personal data, demand compensation for the damage.

you have the rights stated above.

9.           COMMUNICATION METHODS

Within the scope of Law No. 6698, you can realize your rights regarding your personal data by using the following methods;

9.1. HPB Association Contact Information;

You can use the following methods to get preliminary information about your personal data;

Data Controller : TURKISH HEPATO PANCREATO BILIARY SURGERY ASSOCIATION

Telephone         : 0530 325 48 37

Address              : Seyyid Ömer Mahallesi Yaylak Sokak 29/2 Fatih – İstanbul PK: 34098

E-mail                 : hpb@hpb.org.tr

In order to identify the person in your applications and to follow up your legal application period, you must apply using the methods specified under the heading "Relevant Person Application Methods" below.

9.2.       Contact Person Application Methods:

•            Application made by hand to the address: The relevant person fills out the "KVKK Request Form" and submits it to " Seyyid Ömer Mahallesi Yaylak Sokak 29/2 Fatih – İstanbul PK: 34098" in person. He/she must present his/her ID card during the application.

•            Application through a notary public: It is the application made by the relevant person sending the "KVKK Request Form" certified by the notary public to the specified address with return / registered mail or by sending it to the address specified by the notary public.

For mailings to be sent to addresses, registered mail must be sent with return receipt for the smooth follow-up of your thirty-day legal right. Applications within this scope will be accepted following the identity verification to be made by us, and the relevant persons will be responded in writing or electronically within the legal periods.