Privacy of the patient area and of the « Doctor Manager Patient » app

This page is for patients. It describes your practice's patient area and the « Doctor Manager Patient » app for iPhone (and for Android, once it is released). Sections 2 and 3 describe the iPhone app. The general privacy policy of our website (in French) covers visitors to the website and customers of DOCTOR MANAGER (the healthcare professionals): it does not apply to your data as a patient. DOCTOR MANAGER never uses your patient data for prospecting, advertising, market research or improving its products, and never sells or transfers it.

1. Who is responsible

The patient area and the app are offered by your practice. Your practice is the controller of your data: it decides what it shares with you, for what purpose and for how long. Its name appears at the top of every screen and its contact details are under « Contact the practice ». The purposes of this processing (organising your care and communicating with you securely) and its legal basis are those of your practice, which informs you about them.

DOCTOR MANAGER (Sylho Group SA, BE 0681.618.703, 46 avenue du Prince de Ligne, 1180 Uccle, Belgium) provides and hosts the tool on behalf of the practice, as a processor bound by contract: we only process your data on the practice's instructions and to run this service.

2. What the app keeps on your iPhone

- the list of the practices you have added: address of the practice's website, name, colour, logo, and a technical identifier of your access key for that practice;
- the history of the notifications received (general texts, with no medical content).

This information stays on this iPhone: it is stored in the iPhone's Keychain (restricted to this device) or in encrypted files, is not copied to iCloud or to backups, and is erased when you remove a practice, when you use « Erase everything from this iPhone » or when you delete the app. The patient area pages shown in the app are not kept after the app is closed.

3. Your access key (Face ID)

When you add a practice, the iPhone creates an access key (« passkey ») for that practice. Face ID recognition (or the iPhone passcode) is done by the iPhone itself: neither the practice nor DOCTOR MANAGER receives your face or your passcode; the practice only receives the public part of the key. The iPhone stores the key with your passwords; if iCloud Keychain is turned on, Apple syncs it between your devices, end-to-end encrypted. The key shows your first name, the initial of your last name, the words « Doctor Manager » and the date it was created, never the name of the practice.

4. What is sent to your practice

- when you add a practice: the code given to you by the practice and your national number (or your date of birth if you do not have a Belgian number), to check your identity, as well as your agreement to the practice's access conditions;
- the registered device (type of device, date added) and the public part of your access key;
- if you turn on notifications, your iPhone's notification address, provided by Apple (or, with the Android app once it is released, your Android phone's, provided by Google);
- what you choose to send (forms, photos, videos, messages, signatures);
- a security log: sign-ins, documents opened, devices added or removed, signatures, with the date, the type of device and the network address (IP address).

This data is hosted by DOCTOR MANAGER in the European Union (DigitalOcean data centre in Amsterdam, the Netherlands). Our technical providers who may access it for maintenance are on the list of our sub-processors, which your practice can give you.

5. Notifications

Notifications are optional: the app works without them and your practice keeps informing you by e-mail. You can turn them off at any time, practice by practice in the app, or in the iPhone Settings (on Android: in the phone's Settings).

They are delivered by Apple's notification service. Their text is general (« New document available »): it contains neither the name of the practice, nor the title of the document, nor any medical information; the name of the practice is added by the app, on your iPhone. To deliver a notification, Apple receives your iPhone's notification address, this general text, a technical code that does not contain the name of the practice, and the time it was sent: Apple therefore knows that your iPhone receives notifications from the Doctor Manager Patient app. Apple processes this data under its own privacy policy: for people in the European Union, it falls under Apple Distribution International (Ireland), and its transfers to the United States are covered by the European Commission's standard contractual clauses. The notification address is erased at the practice when you turn notifications off.

With the Android app, once it is released, notifications are delivered by Firebase Cloud Messaging, Google's notification service, with the same general text. To deliver a notification, Google receives your phone's notification address, this general text, a technical code that does not contain the name of the practice, and the time it was sent: Google therefore knows that your phone receives notifications from the Doctor Manager Patient app. Google processes this data as a sub-processor of DOCTOR MANAGER, under the Firebase Data Processing and Security Terms; for people in the European Union, it falls under Google Ireland Limited (Ireland), and its transfers to Google LLC in the United States are covered by the European Commission's standard contractual clauses and by the EU-U.S. Data Privacy Framework, under which Google is certified. Here too, the notification address is erased at the practice when you turn notifications off.

6. Camera and microphone

The camera is used to scan the practice's QR code and to take the photos or videos you choose to send; the microphone is only used for the videos you send. The app does not ask for access to your whole photo library.

7. No central account, no tracking

There is no central Doctor Manager account for patients: each practice has its own database and only sees its own access, and DOCTOR MANAGER never links the data of two practices. The list of your practices exists only on your iPhone. The app contains no advertising, no audience measurement tool and no trackers.

8. How long

- on your iPhone: until you remove the practice or the app;
- your access and your devices: as long as your access is open; a removed device is deactivated immediately;
- the security log: 12 months, then it is erased automatically;
- DOCTOR MANAGER backups: 6 months at most;
- your medical record (including the shared documents and what the practice has taken from what you sent): by your practice, for at least 30 years and at most 50 years after your last contact with it, as required by article 35 of the Belgian law of 22 April 2019 on the quality of healthcare practice.

9. Removing a practice, deleting your access

In the app, « Remove from this iPhone » erases the practice from this iPhone and removes this device at the practice. « Delete my access to the patient area » immediately closes your access to that practice's patient area, on all your devices: devices, sessions, codes and links are cut off, and a confirmation e-mail is sent to you. Your medical record is not deleted: your practice is legally required to keep it. The record that your access was closed and the security log (12 months) also remain. Your practice can give you access again later. All the details, and how to do it without the app: Delete your access to the patient area.

10. Your rights

You can ask for access to your data, its rectification or erasure, restriction of processing, object to processing or receive your data in a machine-readable format: contact your practice, the controller (and its data protection officer if it has one). You can also write to us at hello@doctormanager.be: we pass your request on to the practice concerned without delay and help it reply. Erasure does not apply to what the law requires your practice to keep, such as your medical record. You can lodge a complaint with the Data Protection Authority (www.dataprotectionauthority.be).