1.1 We/Us/Medicinfo: the private limited company TWA Medic-Info B.V. (KVK 18060147), with registered office and principal place of business at Dr Anton Philipsweg 31, 5026 RK, Tilburg.
1.2 You: the person using the Medicoo service.
1.3 Another: a person other than yourself, whom you represent, and to whom the healthcare request you make through the Medicoo service relates (for example: your child or someone you formally or informally care for).
1.4 Medicoo App: the app that can be downloaded from one of the app stores. The App is used to start the service and unlocks and/or facilitates the underlying components of the Medicoo service.
1.5 MSC: Medicinfo’s Medical Service Centre, consisting of nurses and GPs.
1.6 MSC Expert: an MSC employee registered in the BIG-register, or who works under the supervision and responsibility of a doctor or nurse registered in the BIG-register.
1.7 Medicoo Service: the Medicinfo service where healthcare questions can be posed in the MSC in a chat format through the Medicoo app, with an option to upload photos. Using a triage process, in-depth questions are asked in order to clarify and assess the healthcare question. The MSC expert then provides a recommendation for self-care, a referral, or a video consultation with a GP. In highly urgent cases, the MSC expert will refer a client directly to the nearest GP, physician, medical centre, or the 112 emergency services.
1.8 GP: general practitioners registered in the BIG-register and involved in the Medicoo service.
1.9 Video Consultation: a video call to be completed in consultation and by appointment with a GP, MSC expert or another healthcare provider.
1.10 Claims: for Dutch users, claims for the costs of using the Medicoo service are declared by Medicinfo directly to the health insurance provider or to the GP offering the Medicoo service. Any foreign holidaymakers using the Medicoo service will receive a claim declaration afterwards via a payment link in the App or via mail, unless the patient has a valid European Health Insurance Card (EHIC).
Foreigners using the Medicoo service will receive a claim declaration afterwards via a payment link in the App or via mail, unless the patient has a valid European Health Insurance Card (EHIC).
2. Use of the Medicoo Service
2.1 You may use this service if your health insurance provider, your own GP, or a medical clinic you visit offers the Medicoo Service. The healthcare request may relate to yourself or to Another.
2.2 You may use the Video Consultation component within the Medicoo Service when the MSC Expert offers it to you as part of the treatment for your healthcare needs.
2.3 After installing the App, explicit consent is requested according to the privacy terms made available there. The processing of personal data can only begin subject to the provision of explicit consent. If the requested consent is not granted, there is no legitimate basis for processing the data and no use may be made of the Medicoo App or the Medicoo Service. The consent granted applies to the processing of your own personal data as well as to the personal data of persons you are legally representing (such as your child).
2.4 During the installation process, you will also set up a PIN code for secure access to the App. An onboarding process will then be carried out where various data necessary for the fulfilment of the service will be requested. The first step is to identify the provider through which you can use the Medicoo Service. In the next steps of the onboarding process, all the necessary personal data will be requested and recorded. When you are using the service on behalf of Another, identifying information about that person will also be requested.
2.5 If you are insured for healthcare in the Netherlands, a COV (insurance record) check will be performed in the background using your BSN (citizen service number) and date of birth. COV stands for ‘Controle Op Verzekeringsrecht’ in Dutch and it is a check to determine whether someone has healthcare coverage. The data must ‘agree’ with that of a health insurance company. This verifies that you are insured for healthcare. If no ‘agreement’ is received, the service cannot be used. One exception to this rule is foreign holidaymakers, who do not go through an insurance record check. For this category of users, Claims may be declared via the European Health Insurance Card (see: ‘Claims’).
2.6 You can ask the MSC Expert questions via the chat. A digital triage is performed initially; see ‘Triage process’. If still necessary, the MSC Expert will then try to further clarify, assess, and answer your healthcare question. Notifications in the App let the customer know that a response has been sent.
2.7 The MSC Expert has the option to discuss your question with a GP at any time.
2.8 Your question may be answered with self-care advice, a referral, or a video consultation. In highly urgent cases, the MSC Expert will refer you directly to the nearest GP, physician, medical centre, or the 112 emergency services.
2.9 If a video consultation is part of the response to your healthcare question, it is usually completed by a Medicinfo GP. The Video Consultation is scheduled and initiated via the App, using a reliable and secure video call solution in your default browser. The GP can view your chat history via the App prior to the call. During the meeting with the GP, your personal request for assistance will be discussed with you. A conversation lasts between 10 to 20 minutes on average and always takes place via video call.
3. Triage process
3.1 In order to clarify your healthcare question in a structured and efficient way, we like to start with a digital triage. Based on the symptom entered (the symptom area clicked), appropriate triage questions will be asked for the symptom area, and these are based on known professional standards for general practitioner care.
3.2 So-called ‘red flags’ may emerge from certain questions. For example, in the case of a headache, we ask whether the headache has come on very suddenly, which may indicate a symptom that needs highly urgent treatment. If a ‘red flag’ emerges, the digital triage will be immediately discontinued, and the case will be taken over by an MSC Expert as highly urgent.
3.3 If no ‘red flag’ emerges, the user will be put in direct contact with an MSC Expert via the chat after completing the digital questionnaire. At that moment, the MSC Expert will have access to all onboarding information, any insurance data from insurance record checks, the questions asked, and the answers given.
3.4 A user can choose to interrupt the digital triage process at any time. The user is then put in direct contact with an MSC Expert via the chat. Digital triage simply replaces the routine triage questions, thereby reducing the chance of error. The overview of questions and answers asked allows the MSC Expert to form an opinion or take action better and faster. In other words, no automatic advice will be provided. The interpretation of the information gathered, and the triage based on this information, is always done by a human being.
4. Medicoo Service conditions and restrictions
4.2 You are responsible for the confidentiality of the information recorded with the App. One way to do so is to keep the PIN set up in the App strictly confidential and to always maintain control of your device.
4.3 All questions with the MSC are answered under the responsibility of nurses and GPs registered in the BIG-register. When an employee registered in the BIG-register is asked a healthcare question, a treatment agreement arises (as per the Dutch Medical Treatment Agreement Act (WGBO).
4.4 The MSC Experts and GPs do not have access to any medical records from the patient’s own GP and/or treatment history. In order to allow the MSC Expert to interpret and supervise the process appropriately, you are responsible for providing accurate, complete, and current data.
4.5 Even if you are a non-native speaker using the Medicoo Service, you are nevertheless responsible for providing the MSC Experts and GPs, regardless of any language barriers, with all the necessary correct, complete, and up-to-date information for adequate care.
4.6 Given the digital nature of this service, MSC Experts and GPs are not able to perform certain examinations (such as physical examinations). If during the chat or Video Consultation it becomes apparent that an additional (physical) examination or treatment is required, the MSC Expert or GP will refer you to the appropriate healthcare provider. In urgent cases, the MSC Expert or GP will refer you to the emergency number 112.
4.7 We are not liable for damages if they are a direct or indirect result of:
a) The (temporary) unavailability of the Medicoo App, the functionality of the Video Consultation, or any other part of the service;
b) Any inaccuracies or omissions in the information you have provided to us;
c) Communication problems with users who are non-native speakers;
d) Unauthorised logins, unless you have already notified us of this;
e) Force majeure on our part as per Article 6:75 of the Dutch Civil Code.
5.1 Not fully satisfied with our services? You can report your complaint to us at firstname.lastname@example.org. Medicinfo has appointed a Complaints Officer and is affiliated with a complaint disputes committee. If the Complaints Officer receives a complaint from you, they will communicate our complaint protocol to you. Here you can read about how your complaint will be handled, so you can rest assured that your complaint will be managed appropriately.
6.1 The costs of the Medicoo Service are borne entirely by your health insurance provider or by the GP or medical centre offering the Medicoo Service (excluding foreigners not insured for healthcare in the Netherlands who are unable to present a valid EHIC, and who are paying themselves). You may, therefore, only use the service if it is offered to you by one of the parties mentioned.
7. Privacy and information security
7.1 We believe that privacy is very important. For this reason, we only process data necessary for using the Medicoo Service. We process personal data according to the applicable privacy legislation: The General Data Protection Regulation (GDPR). All relevant information regarding the processing of personal data can be found in the Privacy Statement in the App.
7.2 Medicinfo organises its information security through an Information Security Management System (ISMS) and is ISO27001 and NEN7510 certified.
8. Termination of Medicoo access/use
8.1 We may terminate use of the Medicoo Service if:
b) Your health insurance provider, GP, or medical centre no longer offer the service;
c) The Medicoo Service is discontinued.
8.2 We may at any time modify, make unavailable in whole or in part (e.g., in the event of a fault, maintenance work, or security incidents), or terminate the Medicoo Service.
A. About this service
This service allows you to ask nurses and doctors questions about your health via the App. This service was developed by TWA Medic-Info BV (hereafter: Medicinfo). Medicinfo is also the party that performs the service and who, in this context, processes your personal data if you use this service.
You can also use this service to ask a healthcare question for another person, such as your child or someone else you care for. In that case, the conditions of this Privacy Statement apply to both you and the person to whom the question relates.
When using the Medicoo Service, your may be case eligible for a digital consultation with a GP, i.e., via video call. In this case, you can choose whether to make use of a Video Consultation.
Medicinfo’s clients (including health insurance providers) enable you to use these services, but these parties are not usually involved in any way themselves. They also have no access whatsoever to personal and medical data that can be traced back to individual persons.
One exception to this rule is when the Medicoo Service is offered by your own GP, GP practice, or medical centre and they also play a role in implementing the service, is informed about it (with your permission), or they declare the transaction performed (via EHIC) to your own foreign health insurance provider.
Medicinfo determines the entire interpretation and implementation process of the Medicoo Service and is therefore the so-called processor in the sense of the General Data Protection Regulation (GDPR) for the processing of personal data. The contact details for Medicinfo are as follows:
- Postal address: Dr Anton Philipsweg 31, 5026 RK, Tilburg
- Email address: email@example.com
In the case of a Video Consultation with a GP, the GP is independently responsible for conducting the Video Consultation. Personal data is then processed on the basis of the treatment agreement with the GP, which either already exists or was established during the first (video) consultation.
There is joint responsibility when it comes to determining, recording, and verifying the identity of the patient: Medicinfo requests and records your ID information, and the GP uses it to verify your identity.
C. Data Protection Officer (hereinafter: DPO)
Medicinfo has appointed a DPO to ensure that the processing of personal data takes place in a secure manner, in accordance with the requirements and guidelines set by law. You can direct any questions about the privacy aspects of data processing to the DPO. The contact details for the DPO are as follows:
- Postal address: Medicinfo Attn: the DPO, Dr Anton Philipsweg 31, 5026 RK, Tilburg
- Email address: FG@medicinfo.nl
We are committed to protecting your privacy. In this Privacy Statement, we inform you about matters such as (1) the personal data that we process in the App, (2) the purposes for which we use personal data, (3) the legal basis for processing, (4) where we store personal data and how long we keep personal data, (5) the parties with which we may share personal data, (6) your rights and how you can exercise them, and (7) the security of personal data.
1. The personal data that we process
We process the following personal data concerning you and/or the person for whom the healthcare request is made:
- First name + Last name;
- Date of birth;
- Citizen Service Number (BSN);
- insurance details;
- Phone number.
If you are not insured for healthcare in the Netherlands but are insured in another country within the EEA, we will also process these data:
- EHIC (European Health Insurance Card) identification number;
- Email adress;
- Name of your health insurance provider;
- Identification code of your health insurance provider.
We will also process the following special and/or sensitive personal data:
Questions you have asked in the App and responses to them from us regarding your health (if applicable);
Any photos that you may upload containing health information and which are traceable to an individual.
Note: You can, of course, choose what you do and do not want to share through the App.
If a Video Consultation is part of the service, we are obliged under the Act on the Use of the Citizen Service Number (BSN) in Healthcare (Dutch: Wgbsn-z) to check and register the patient’s identity and BSN. We are also required to verify the identity of the patient in case of a claim made through the EHIC. We use the data entered in the App for this purpose, record this data, and make it available to the GP. The GP will then ask you, or the person for whom the healthcare request is made, to identify yourself during the Video Consultation by showing the requested ID to the camera. In the case of a Video Consultation, we will therefore process the following personal data (in addition to the BSN):
ID type (driving licence/ID card/passport);
Identity document number.
2. What we use the personal data for
Medicinfo processes personal data for the following purposes:
to implement the various services offered, especially the provision of tailored information or advice;
to communicate medical information to one’s own GP (if permission is granted);
to make a claim for the transaction performed;
to analyse the use of the App in order to improve its functionality;
to improve the quality of our services.
And, in the case of a Video Consultation:
to establish the identity and BSN of the patient in the context of the Dutch Wgbsn-z.
3. The legal basis for data processing
Medicinfo may only process personal data if there is a legitimate legal basis for doing so. This legal basis, in the case of this App, is that you have given your explicit consent to Medicinfo processing your data, or the data of someone you legally represent, when using the services upon installing the App (by agreeing to this privacy statement).
4. Where we store personal data and how long we retain personal data
The personal data we process is stored on servers hosted in Europe.
Medicinfo does not retain personal data longer than strictly necessary to achieve the goals for which the data is collected. Our retention periods are:
6 months, if the data is only used for the purposes of improving the quality of our
20 years, if the data is part of a treatment relationship and thus falls under the
mandatory minimum retention period for medical records.
After the expiration of the retention period, the data will be deleted or adequately anonymised.
5. The parties with whom we may share personal data
Medicinfo never sells the data to third parties and will only provide it to others if necessary for the provision of services or to comply with a legal obligation.
The Medicoo Service is performed entirely under the responsibility of Medicinfo. If other parties are involved in implementation (e.g., by hosting the applications that register the personal data), Medicinfo has entered into a processor agreement with these parties that sets out the requirements for the implementation of the service. Your medical questions are answered at Medicinfo by nurses and doctors registered in the BIG-register. Medicinfo staff have all signed confidentiality agreements.
Medical information related to your healthcare needs may be shared with your own GP, but only if you do not object to this. When you have a Video Consultation with a GP, Medicinfo passes the previously listed ID information to the GP who will be doing the Video Consultation with you.
Data may be shared with researchers in order to research the use or operation of the
service. Anonymised data will always be used for this purpose, or else only after explicit permission has been obtained.
If a health insurance provider allows you to use the Medicoo Service, they will never be able to learn of medical information that can be traced to individual persons and that is processed through the App or the underlying service. Medicinfo may provide data about the use of the service with the party concerned, but this does not include personal data and it certainly never contains medical information that can be traced back to individual persons.
If the Medicoo Service is offered by your own GP, GP practice, or a medical centre, then the service is provided in collaboration with this party. In some situations, this party may take an active role in the service itself and may therefore have access to your medical records. In some cases, the party has no active role but will be informed through a consultation report, though only if you do not personally object to this. When a claim for the transaction performed is declared to your own foreign health insurance provider (via EHIC), they will, of course, be able to see the transaction performed for which reimbursement has been requested.
6. What are your rights and how can you exercise them?
Accessing and correcting your personal data
You have the right to access your personal data that we process and to see what we use it for. You can view the data on your phone via the installed App. You may also want to see what information Medicinfo has recorded about you. You can submit a request to do so. Please specify the information you would like to receive and why. You also have the right to correct your personal data if the data we process about you is incorrect.
You may only use this service if you have given your explicit consent based on the Privacy Statement when installing the App. You can always revoke your consent but taken together with the overall agreement for the App, this will terminate your use of the service. You can then remove the App from your device yourself.
Please note that withdrawing your consent is not retroactive and therefore does not affect processing operations that have already been carried out.
Deleting your personal data
You have the right to ask us to delete your personal data. If, for example, the
personal data is no longer needed for the purposes for which we collected/processed it, or if you withdraw your consent regarding the use of your personal data. In your request, please state which data you would like removed and why.
You have the right to receive the personal data we process from us in a
structured, standard, and machine-readable form, if such personal data has been provided to us by you or on your behalf and has been used by us in automated systems.
Exercising your rights
If you wish to invoke any of the rights above, you may submit a request to the Medicinfo DPO using the contact details provided. We will respond as soon as possible within one month at the latest. If responding to your request will take more time, we will also inform you of this within one month.
To ensure that the request to access, correct, or delete data has been made by you, we will contact you and ask for confirmation. In doing so, we may ask you to show proof of identity to verify that it is indeed your data.
7. Personal data security
Medicinfo takes the protection of data very seriously and takes appropriate measures to prevent misuse, loss, unauthorised access, unwanted disclosure, and unauthorised changes. Medicinfo organises its information security through an Information Security Management System (ISMS) and is ISO27001 and NEN7510 certified.
All employees of Medicinfo and employees of any processors involved who may have access to your data have been screened, have a positive certificate of good conduct (VOG) and have signed a confidentiality agreement. All nurses and doctors are also bound by medical confidentiality through their registration in the BIG-register.
If you feel that your data has not been properly secured after all, or if there are indications of misuse, please contact the Medicinfo DPO immediately.
Medicinfo has appointed a Complaints Officer and established a complaints protocol. If you have a complaint regarding our services, you can address it to the Complaints Officer at:
- Postal address: Medicinfo, Attn: Complaints Officer, Dr Anton Philipsweg 31, 5026 RK, Tilburg
- Email address: firstname.lastname@example.org
Upon receipt of your complaint, the Complaints Officer will inform you of how your complaint will be further handled. If your complaint has not been managed satisfactorily by Medicinfo, the complaints protocol indicates how to proceed. Medicinfo is affiliated with a disputes committee for such cases. If applicable, the complaints protocol will be sent to you by the Complaints Officer, but it can also be found on the Medicinfo website.
If your complaint pertains specifically to the processing of your personal data, you may also direct your complaint to Medicinfo’s DPO, with the option to escalate it via www.autoriteitpersoonsgegevens.nl.
F. About this Privacy Statement
Medicinfo may change this Privacy Statement. This is allowed, for example, when there is a change to the laws or regulations, or if we change a process or develop new products or services. You will always find the latest version in the AppE.