Patient Privacy Notice

Who is responsible for your data

The clinic treating you is the data controller: it decides why and how your data is used, and it is the organisation legally answerable for it. Kairo is the software the clinic uses to run its practice — we act only as a data processor, on the clinic's documented instructions and under the contract required by Article 28 GDPR. We do not decide what your data is used for and we never use it for purposes of our own.

This means every request about your data — a copy, a correction, a deletion, a withdrawn consent — goes to your clinic. The clinic's own privacy notice names its data protection officer or contact point, where one is appointed.

What the form collects

The appointment information form asks only for what the clinic needs to open and keep your file correctly. It does not ask about your clinical history: anything concerning your health is recorded by the clinic during your care, not by this form.

• Identity — first name, surname, date and place of birth, and gender where the clinic records it.
• Contact details — email address and telephone number, used to reach you about your appointments and your care.
• Residence — your address and country of residence, which also determine which of the consents below apply in your case.
• Tax code — your Italian codice fiscale, or the equivalent foreign tax identifier, which Italian law requires for healthcare invoicing and for reporting healthcare expenses.
• Health-record identity — where applicable, the details needed to identify you in the Fascicolo Sanitario Elettronico (FSE), Italy's national electronic health record.
• The appointment itself — its date, the branch, and the reason for the visit as the clinic recorded it when it sent you the link.

Why your data is used, and on what legal basis

Every use has a legal basis under the GDPR. For the data collected through this form there are three:

• Providing your care. Your identity, contact and clinical data are used to plan, deliver and document your dental treatment. The legal basis is Article 6(1)(b) and, for health data, Article 9(2)(h) GDPR — processing necessary for healthcare provided by, or under the responsibility of, a health professional bound by professional secrecy.
• Complying with the law. Your tax code and billing data are used to issue invoices, to transmit healthcare expenses to Sistema Tessera Sanitaria for the pre-filled tax return, and to keep the records Italian law requires. The legal basis is Article 6(1)(c) GDPR — a legal obligation the clinic is subject to. You cannot object to this use; the clinic has no choice about it.
• Your consent. Consultation of your Fascicolo Sanitario Elettronico rests on your consent — the legal basis is Article 6(1)(a) and Article 9(2)(a) GDPR. The clinic separately records your decision about contributing documents to your FSE, and transmits nothing to it without one. The legal characterisation of that second decision is under review with the clinic's advisers, because Italian law on contributing to the FSE has changed since consent was first required for it; this notice will be corrected when that review concludes. These are the only parts of the form that record a consent, and the only parts you can withdraw.

The FSE consents, explained

The Fascicolo Sanitario Elettronico (FSE) is the national electronic health record kept by the Italian regions. It gathers the documents produced by the health professionals who treat you, so that the next one has your history. Submitting the form may record two separate decisions about it — but only if you are resident in Italy and your clinic uses the FSE. If either condition is not met, neither consent is recorded, and the wording shown on the form says so rather than claiming a consent that will not be captured.

• Consultation consent — you allow the clinic's practitioners to look at the documents already in your FSE, so they can see your relevant medical history before treating you. Without it, they work only from what you tell them.
• Feeding consent — you allow the clinic to add the documents it produces about your care to your FSE, so that other health professionals who treat you later can see them. Without it, your dental documents stay with the clinic and are never sent to the FSE.

If you are resident in Italy and your clinic uses the FSE, accepting both is currently required to submit this form: the single confirmation records both, and the form will not let you submit while refusing them. If either condition does not apply to you, neither consent is recorded and neither is asked of you. You can withdraw either, or both, at any time afterwards by telling the clinic — and withdrawing has no effect whatsoever on your treatment: the clinic will see you, treat you and invoice you exactly the same way. Neither consent gives anyone new access to the data the clinic itself holds. Whether this confirmation should be required for the two FSE consents is under review with the clinic's advisers.

You can withdraw either consent at any time by telling the clinic. Withdrawal takes effect from the moment it is recorded and does not make earlier, lawful use unlawful. Documents already in your FSE remain governed by the FSE's own rules, which include your right to obscure individual documents (oscuramento). This form never asks you to obscure anything — that decision is separate, is always yours, and is made with the clinic or through your regional FSE services.

What ticking the confirmation records

The form will not let you submit until you tick the confirmation. What that single tick records depends on your situation, and the wording shown to you describes only what will actually be recorded in your case:

• Always — that this notice was shown to you and that you acknowledged it, stamped with the date of your submission and with the version of the notice in force at that moment.
• In addition, if you are resident in Italy and your clinic uses the FSE — your consultation consent and your feeding consent, both as granted.

Nothing else is inferred from the tick. No obscuring decision is recorded, and no consent is ever recorded on someone else's behalf: the record states that you declared it yourself, alongside the staff member who sent you the link.

If you had previously told the clinic you were withdrawing one of these consents, ticking the box does not quietly reinstate it. The withdrawal stands, and the disagreement is flagged to the clinic's staff so that a person, not a form, decides.

If the clinic cannot immediately match your submission to your file, your answer is held with the submission and recorded as soon as a staff member completes the match. You are not asked again.

Who else receives your data

Inside the clinic, your data is seen by the staff who need it for your care, your appointments and your invoices — each of them bound by confidentiality.

Outside it, your data reaches a small number of third parties: technical providers acting on the clinic's and Kairo's instructions under Article 28 GDPR (hosting, email, electronic invoicing, messaging), and the Italian public bodies we are legally obliged to transmit to, such as Sistema Tessera Sanitaria and the Sistema di Interscambio. Where the FSE consents apply, the regional FSE infrastructure also receives the documents concerned.

We do not repeat that list here, so that the two can never drift apart. It is published in full, and kept current, on our sub-processors and data recipients page.

See our Sub-processors & Data Recipients →

Where your data is kept, and for how long

Your data is hosted on servers in the European Union. A few of the providers listed on our sub-processors page operate global networks; that page names each of them and the region it operates in.

How long your data is kept is decided by the clinic as data controller, within the limits Italian law sets. In broad terms: clinical records are kept for as long as the care relationship requires and thereafter for the periods professional and health rules impose; accounting and invoicing records for ten years (art. 2220 of the Italian Civil Code); and the record of your acknowledgement and consents stays with your file as evidence of the decisions you took. A submission the clinic cannot match to a file is held only until a staff member resolves it.

When your data is erased, the record of your consents is erased with the rest of your file — it is not kept separately.

Your rights

The GDPR gives you rights over your data. Articles 15 to 22 cover:

• Access (Art. 15) — to be told what data is held about you and to receive a copy of it.
• Rectification (Art. 16) — to have inaccurate data corrected and incomplete data completed.
• Erasure (Art. 17) — to have your data deleted, except what the clinic must keep by law, such as invoicing records, or for the establishment or defence of legal claims.
• Restriction (Art. 18) — to have use of your data limited while a dispute about its accuracy or lawfulness is resolved.
• Portability (Art. 20) — to receive the data you provided in a structured, machine-readable format, and to have it sent to another provider where technically feasible.
• Objection (Art. 21) — to object to uses based on legitimate interests.
• Withdrawal of consent (Art. 7(3)) — to withdraw either FSE consent at any time, without giving a reason and without any effect on your care. Withdrawal does not affect the lawfulness of use before it.

To exercise any of these, contact your clinic — it is the data controller and the only party that can act on your file. Kairo, as processor, forwards to the clinic any request it receives directly. The clinic must answer without undue delay and in any event within one month.

If you believe your data has been mishandled, you may lodge a complaint with the Garante per la protezione dei dati personali (www.garanteprivacy.it), the Italian supervisory authority, or with the authority of your EU country of residence.

Automated decisions and marketing

The data collected through this form is not used to take automated decisions producing legal effects or similarly significant effects on you, and it is not used for profiling. It is not used for marketing: the clinic contacts you about your appointments, your treatment and your invoices — not to sell you anything on the strength of this form.

Questions about this notice

If anything here is unclear, ask your clinic before you submit the form — you are entitled to understand what you are agreeing to. The clinic's full privacy notice, which covers your care as a whole and not only this form, is available from the clinic on request.