GDPR COMPLIANCE PORTAL FOR HEALTH INSURANCE COMPANIES

Privacy Policy for Health Insurance Providers

Effective: 1 May 2025

1. Introduction

We, the (“Entity”), are committed to the protection of your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and applicable insurance and health data laws. This policy explains how we collect, process, and secure personal data for underwriting, claims management, and service delivery.

2. Data Controller

The Entity is the Data Controller responsible for all data collected in the course of providing insurance services.

3. What Personal Data We Collect

We collect and process:

• Identification Data: Name, national ID/passport number, date of birth, gender

• Contact Information: Address, phone, email

• Health Information: Diagnoses, medical reports, treatment records, prescriptions (as needed for claims)

• Policy and Claims Data: Policy details, claims history, billing information

• Payment Data: Bank account, credit/debit card details, reimbursement transactions

• Employer/Corporate Group Data: If insured under a group or occupational scheme

• Children’s Data: Processed only under legal guardianship with verified consent

4. Lawful Basis for Processing

We process data based on:

• Consent (Art. 6(1)(a), 9(2)(a)) – for certain health disclosures and profiling

• Contractual Necessity (Art. 6(1)(b)) – for policy issuance and claims

• Legal Obligation (Art. 6(1)(c)) – compliance with insurance, tax, and audit laws

• Legitimate Interests (Art. 6(1)(f)) – fraud detection, internal reporting (with assessments)

• Health Data Processing (Art. 9(2)(h)) – for claims, pre-authorizations, and reimbursements

5. Purposes of Data Processing

We use personal data to:

• Underwrite health insurance policies

• Assess and process claims and reimbursements

• Verify identity and determine eligibility

• Prevent and detect fraud

• Comply with tax, audit, and regulatory requirements

• Communicate policy updates, renewals, and service alerts

6. Data Sharing and Recipients

Data may be shared with:

• Medical professionals and facilities (for pre-authorization or validation)

• Third-party administrators and claims processors

• Reinsurers and underwriters

• Government agencies, regulators, and tax authorities

• IT, cybersecurity, and CRM service providers

All third parties are bound by GDPR-compliant Data Processing Agreements under Article 28.

7. Data Retention

• Policy and Claims Records: Retained for 10 years after policy lapse or final claim resolution

• Payment and Transaction Data: Retained for 6–10 years for compliance

• Fraud or Audit Files: May be retained longer under legal exemption

8. Data Subject Rights

You may exercise the following rights:

• Access (Art. 15)

• Rectification (Art. 16)

• Erasure (Art. 17), where applicable

• Restriction (Art. 18)

• Data portability (Art. 20)

• Objection (Art. 21)

• Withdraw consent (Art. 7(3))

Contact our DPO at: [DPO Contact Information]

9. International Transfers

Where claims or systems are managed internationally, we use:

• EU Standard Contractual Clauses (SCCs)

• Adequacy decisions

• Risk assessments and secure encryption

Transfers are clearly documented and minimized where possible.

10. Data Security

Measures include:

• Claims portal encryption (TLS)

• Multi-factor authentication for access

• Segregation of health and financial data

• Internal and external audits

• Fraud monitoring systems with alert triggers

11. Data Breach Notification

We notify the relevant Supervisory Authority within 72 hours and impacted individuals if there’s a high risk to their rights.

12. Automated Decision Making

We may use automated systems to assess eligibility or detect fraud, but significant decisions are reviewed by a human assessor.

13. Data Protection Impact Assessments (DPIA)

DPIAs are conducted for:

• AI-based fraud detection

• New claims technologies

• High-volume health data processing

14. Cookies and Website Tracking

We use cookies and similar tracking technologies strictly for essential website functionality, security, and analytics. No profiling or advertising cookies are used without your prior explicit consent.

15. Complaints

You may lodge a complaint with your Supervisory Authority if you believe your rights are infringed via CONTACT SUPERVISORY AUTHORITY below.

16. Use of Artificial Intelligence (AI) and Automated Tools

We may use Artificial Intelligence (AI) or automated technologies to support the delivery, analysis, or improvement of our services. Any deployment of AI is conducted in accordance with applicable laws, including the GDPR and forthcoming EU AI Act, and is subject to the following safeguards:

• Transparency: Where AI tools are used to process personal data (e.g., chatbots, service optimization, fraud detection), individuals are clearly informed at the point of interaction.

• Human Oversight: All AI-supported functions are subject to human review and final decision-making. No fully automated decisions with legal or similarly significant effects are taken without human intervention.

• Fairness and Accuracy: AI systems used by the Entity are regularly monitored to ensure outputs are non-discriminatory, accurate, and aligned with intended purposes.

• Data Minimization: Personal data used in AI models is limited to what is strictly necessary, and anonymization or pseudonymization is applied wherever feasible.

• Third-Party AI Providers: If AI services are sourced from external vendors, they are required to comply with our data protection standards and are bound by GDPR-compliant agreements (Art. 28).

• Rights of Individuals: Data subjects retain all applicable GDPR rights, including the right to object to automated processing (Art. 21) and to receive meaningful information about the logic and implications of any AI-supported decisions (Art. 22).

This clause will be updated as legal frameworks governing AI continue to evolve.

17. Updates
This policy is reviewed annually and updated to reflect changes in law or service station operations.

We the ENTITY take your privacy seriously and treat your personal information with the same care and respect we would expect for our own. This policy has been developed to comply with relevant data protection laws in our jurisdiction and, where necessary, with those of other applicable regions. If you have any concerns or identify areas where you feel we may not be meeting our responsibilities, please don’t hesitate to get in touch using the contact methods listed at the end of this policy. We are committed to addressing any issues promptly and transparently.

A specialized compliance team has created this policy

1. Data Protection Officer (DPO) – Regulatory Oversight

• Ensures all policies strictly adhere to GDPR principles (lawfulness, transparency, data minimization, etc.)

• Coordinates legal review of lawful basis, data subject rights, international transfers

• Leads DPIA structure and breach protocols

2. Healthcare Compliance Specialist – Clinical & Sector-Specific Accuracy

• Aligns policies for clinics, hospitals, diagnostic labs, and CROs with EU healthcare-specific laws (e.g., MDR, IVDR)

• Validates handling of health data, pseudonymization, and patient consent

3. Cybersecurity Expert – Data Security & Technical Controls

• Reviews and enhances sections on encryption, access controls, breach response

• Assesses vulnerabilities in telemedicine, HealthTech, and device ecosystems

4. Clinical Trials Legal Advisor – Research & Ethics Governance

• Provides expert review of consent models, data minimization, and pseudonymization in CRO/trial sponsor contexts

• Validates retention and secondary use of trial data

5. Insurance & Claims Data Analyst – Financial & Claims Compliance

• Reviews insurance provider policy to ensure lawful processing of medical + financial data

• Checks fraud detection profiling, cross-border reinsurance handling

6. Social Care & Safeguarding Expert – Care Facilities Privacy

• Ensures care home, mental health, and disability service policies reflect safeguarding, social care, and public interest standards

7. Occupational Health Specialist – Employment Health Interface

• Validates lawful employer data access, fitness for work processing boundaries, and health/safety recordkeeping

8. Medical Device Regulatory Consultant – MDR/IVDR Alignment

• Ensures policies for device providers include obligations under EU Medical Device Regulation and post-market surveillance practices

9. Digital Health & AI Legal Advisor – Emerging Tech Compliance

• Checks AI/algorithmic decision-making disclaimers in telemedicine & HealthTech

• Ensures policies reflect EU AI Act intersections where applicable

10. Cross-Border Transfers Specialist – International Data Governance

• Verifies compliance mechanisms for SCCs, BCRs, and adequacy decisions across all entities transferring data internationally