Patient Information Notice
How to use this template
This notice is provided by Lava Labs SRL, the publisher of Anamnesix, for doctors who use the app as their own personal notebook about the patients they treat. Anamnesix belongs to the doctor, not to a clinic or hospital. Replace every placeholder in square brackets with your own details and hand the notice to your patients, show it in your consultation room or attach it to the information each clinic already gives them. It covers only the notes you keep in Anamnesix; the official medical record of each clinic or hospital where you work has its own notice.
Information on the processing of your personal data
Dr [Doctor's name], [specialty], contact [Doctor's email or phone], is the controller of the personal data described in this notice. I keep these notes personally, independently of the clinics or hospitals where I see you.
I use Anamnesix, an application installed on my own phone, to keep a private note of your history and of our consultations. Doctors who work in several places often end up with information about a patient spread across messages, calls and paper. The app lets me keep that information in one encrypted place so that I can follow your care properly wherever I see you. It is a personal working file; it does not replace the medical record kept by the clinic or hospital, and nobody else has access to it.
1. What data I record
- Identification and contact details: name, date of birth, sex, phone number and a patient number I assign.
- Health data: reason for consultation, history, examination findings, diagnoses, treatment plans, allergies, conditions, surgeries, family history, lifestyle factors, medication, laboratory results, pregnancy follow-up where applicable, and photos of documents and reports you show me.
- Voice memos: notes I dictate after or during a consultation, and their written transcript.
I do not record your personal numeric code (CNP) or insurance number in the app.
2. Why I process your data and on what legal basis
I process your data to provide you with medical care and to follow your treatment over time, including when I see you in different clinics. The legal basis is the provision of health care by a professional bound by professional secrecy, under Article 9(2)(h) of the GDPR, together with the Romanian laws on patient rights and professional secrecy.
I do not need your consent to keep these notes. I do ask for your agreement before recording your own voice during a consultation; you may refuse without any effect on your care.
3. How your data is protected
- The notes are stored on my phone in an encrypted database. Documents and voice memos are encrypted individually. The app is locked with a PIN and, where enabled, fingerprint or face recognition, and locks itself automatically.
- With my subscription, an encrypted copy of the notes is backed up to servers in the European Union. The copy is encrypted before it leaves the phone, and the keys exist only on the phone. The app publisher cannot read the backup.
- Voice memos are transcribed by a transcription provider in the European Union, acting on my behalf under a data processing agreement. The recording and the transcript are deleted at the provider as soon as my phone has received the transcript.
- The app publisher, Lava Labs SRL, acts as my processor under a written agreement and does not use your data for any purpose of its own.
4. Who receives your data
Only I have access to the notes. The app has no sharing feature: it cannot send your data to a clinic, to a colleague, to a laboratory or to you. Clinic staff do not have access to it. Encrypted copies are stored by the app publisher's cloud provider in the European Union, and voice memos are processed by the transcription provider in the European Union, in both cases on my behalf and without the ability to read your file. The full list of the app publisher's providers is published at https://anamnesix.com/sub-processors.
Your data is not transferred outside the European Union, is not used for advertising and is not sold.
Whatever I am required by law to report to health authorities or to record in a clinic's medical record, I do through that clinic's own systems, not through this app.
5. How long I keep your data
I keep the notes for as long as I am involved in your care, and no longer than the retention period that applies to a doctor's own patient notes under Romanian law, which is [TODO: retention period applicable to the doctor's notes]. When I delete a note, it is removed from the phone and from the encrypted backup at once. Voice recordings are kept only as long as they are needed for the written note and are deleted afterwards.
6. Your rights
You have the right to:
- access your data and receive a copy of the notes I keep about you;
- have inaccurate data corrected;
- ask for deletion where the law allows it;
- restrict or object to processing in certain cases;
- receive the data you provided in a portable format;
- refuse the recording of your voice, or withdraw your agreement for future recordings.
To exercise your rights, contact me at [Doctor's email or phone]. I answer within one month.
You may lodge a complaint with the Romanian supervisory authority: Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP), B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, Bucharest, www.dataprotection.ro.
7. Contact
Dr [Doctor's name], [specialty], [Doctor's email or phone].
Agreement to voice recording (optional)
I, [Patient name], have been informed that Dr [Doctor's name] may record my voice during the consultation for the purpose of documenting personal notes about my care, and that the recording is transcribed by a provider in the European Union on the doctor's behalf and deleted after transcription. I agree to the recording of my voice. I understand that I may refuse or withdraw this agreement at any time without any effect on my care.
Date: [Date] Signature: [Signature]