National Health Service Contact Centre
The National Health Service Contact Centre (SNS 24), also known as SNS 24, is a telephone and digital service of the National Health Service (SNS), created to help you with your health questions and offers you a set of services that allow you to avoid trips to the health centre or hospital.
The operation of SNS 24 is ensured by SPMS, E.P.E. – Shared Services of the Ministry of Health, E.P.E. (SPMS, E.P.E.), which is committed to the observance of the best practices in terms of security, privacy and protection of the personal data of the users of this service, adopting several measures of a technical and organizational nature, aimed at ensuring that the respective information enjoys a level of security appropriate to the risk.
As such, SPMS, E.P.E. informs you of its privacy policy, aimed at informing you of your rights and clarifying how your personal data is collected and used within the scope of the SNS 24 activity.
The use of the services provided by SNS 24, as well as the completion of any forms available on the respective website and the direct or indirect provision of data, implies knowledge of the conditions defined in this policy.
1. Responsible for the processing of personal data
SPMS, E.P.E. is the entity responsible for the processing of personal data carried out within the scope of the SNS 24 activity, defining the data collected, the means of processing and the purposes for which such data will be used.
As data controller, SPMS, E.P.E.:
- You ensure that the processing of your personal data is carried out only within the scope of the purposes for which they were collected or for purposes compatible with those purposes;
- Collects, uses and stores only data that is adequate, relevant and limited in relation to the purposes for which it is processed;
- It does not transmit data for commercial or advertising purposes.
2. Data Protection Officer
SPMS, E.P.E. has appointed a Data Protection Officer.
The Data Protection Officer of SPMS, E.P.E. can be contacted for clarification of any doubts or for the submission of complaints, through the following email address: dpo@spms.min-saude.pt
Without prejudice to complaints filed with the data protection officer, the data subject may also submit their complaints to the National Data Protection Commission (CNPD).
3. Personal data, data subjects, categories and form of collection
3.1 Personal data
Under the terms of the applicable legislation, personal data is considered to be any and all information relating to a natural person, identified or identifiable. In this sense, an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier. Examples of identifiers are: a name, an identification number, location data, online identifiers or one or more elements specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Certain personal data is of a particularly sensitive nature and is classified by the General Data Protection Regulation (GDPR) as "special categories of data". Special categories of personal data include data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as the processing of genetic data, biometric data to uniquely identify a person, data relating to health or data relating to a person's sex life or sexual orientation.
Health data is considered to be data relating to the state of health of the data subject, which reveal information about his or her physical or mental health, in the past, present or future. Health data includes:
- Information about the person collected during registration for or during the provision of health services;
- any particular number, symbol or sign assigned to a natural person to uniquely identify him or her for healthcare purposes;
- information obtained from analyses or examinations of a body part or a body substance, including from genetic data and biological samples;
- Any information about, for example, a disease, disability, a disease risk, medical history, medical treatment or physiological or biomedical status of the data subject, regardless of its source, for example a doctor or other healthcare professional, a hospital, a medical device or an in vitro diagnostic test.
3.2 Personal Data Subjects
The holders of personal data are the natural persons to whom the personal data relate and who use or intend to use the services provided by SNS 24.
3.3 Categories of personal data processed
Within the scope of the services and channels provided by SNS 24, the following personal data may be collected:
|
< />Category of processed data |
|
|---|---|
|
Demographics and identification |
Such as voice, image, name, surname, date of birth, language of service, address, postal code, city, telephone, email, fax, user number, health subsystem, health center, NISS, NIF. |
|
Administrative Data |
Such as exemption from user fees or appointments. |
|
Health Data |
Data related to the physical or mental health of users, such as symptoms, referrals to a health unit, medication, appointment scheduling, surgery vouchers, psychological counseling, results of self-tests. |
|
Data for continuous service management and improvement and audit data |
Such as call recording, ID of the call made to SNS 24, contact telephone, date and time of contact, duration, waiting time, identification data of the person who made the call, district, relationship with user, initial intention, reason for the call, algorithm, guidance, comment, referral health unit, follow-up, time when the follow-up call was made, date and time of the callback, type of service, date and time of the reply to the written contact. |
3.4 Time and manner of data collection
Your personal data may be collected in the following circumstances:
- Directly with the user, when interacting with the Contact Center operator, through the channel or means of communication that is being used at the time;
- Directly with the user, when interacting with SNS 24, via telephone, video call, webchat or through the website itself;
- Directly with the SNS databases, when triage, counseling or referral carried out by SNS 24 via telephone, video call or webchat;
4. Purposes and basis of data processing
Within the scope of the services provided by SNS 24, SPMS, E.P.E. processes your personal data for the following purposes:
- For the provision of healthcare(1): your data identified above is processed for the purposes of clinical triage, counselling and referral and for the provision of telecare services. < />The processing of data necessary for the achievement of the purposes described here will be based on your consent, expressed when using the services provided by SNS 24. The processing of such information may also be based on the management of the health services provided by SPMS, E.P.E. through SNS 24.
- For the provision of public health care and for general health information: your data may be processed by SPMS, E.P.E. for the purpose of providing public health support and for the provision of general health information.
Such data are processed based on your consent, expressed when using the services provided by SNS 24. - For the provision of information or administrative services: SPMS, E.P.E. may process your data within the scope of non-clinical informational contacts, related to the provision of clarifications on the services available online. Your data may also be processed within the scope of non-clinical administrative contacts, namely for the purpose of scheduling appointments, for requesting exemption from user fees or for other administrative operations that increase the speed and ease of contact with the SNS.
Such data are processed based on your consent, expressed when using the services provided by SNS 24. - To communicate and manage our relationship with you: SPMS, E.P.E. may contact you by phone, email or SMS, for administrative or operational reasons. Your data will also be processed to respond to your requests, complaints, suggestions or contacts, improving our services and your experience as a user of them.
Such data are processed based on your consent, expressed when using the services provided by SNS 24. - For management, auditing and continuous improvement of the services provided: the personal data processed within the scope of SNS 24 are used by SPMS, E.P.E., for example, for fraud detection and analysis, for statistical studies or for the development and maintenance of information systems.
The lawful basis of such data processing is the pursuit of the legitimate interests of the data controller. Your data may also be processed based on your consent, expressed when using the services provided by SNS 24. - To comply with legal obligations: the data may be processed to comply with obligations to provide information to other entities of the Ministry of Health and Public Administration, as well as to Courts and criminal police bodies, in the exercise of their respective duties and powers. < />The processing of your data is based on compliance with the aforementioned legal obligations.
5. Retention period of personal data
The personal data of SNS 24 users are processed in compliance with the applicable legislation, and are stored in databases specifically created for this purpose. Such data shall be kept in a format that allows the identification of the data subjects only for the period necessary to pursue the purposes for which they are processed.
In the absence of a legal obligation that requires the data to be kept for a specific period, they will be kept by SPMS, E.P.E. only for the period necessary to fulfil the purposes for which they were collected.
6. Transmission of personal data
Suppliers and/or service providers are bound to SPMS, E.P.E. by contract and may only process their personal data for the purposes set out therein, and are prohibited from using, transferring, disclosing or recording the holder's personal data for any purpose other than that for which they were specifically contracted (or without their consent, as applicable).
Within the scope of the services provided by SNS 24, SPMS, E.P.E. may also relate to third parties, which implies access, by these entities, to users' personal data. SPMS, E.P.E. may transmit to third parties(2) the personal data collected within the scope of the CCNSNS when:
- (a)has obtained the consent of the data subject to do so, in accordance with the data protection legislation currently in force;
- Such transmission is carried out in compliance with a legal provision or court order, a resolution of the National Data Protection Commission or a legitimate and reasoned request from entities of the Ministry of Health or Public Administration;
- such transmission is carried out in order to protect the vital interests of the data subject;
In any of the situations identified above, SPMS, E.P.E. undertakes to take the necessary and reasonable measures to ensure the protection of the personal data in question.
7. Rights of personal data subjects
SPMS, E.P.E. guarantees respect for the rights of the holders of personal data, under the terms and within the limits provided for in the legislation in force on data protection.
In accordance with the aforementioned legislation, the data subject may request access to and rectification of the personal data concerning him/her, as well as obtain from the controller the restriction of the respective processing, directly through the email dpo@spms.min-saude.pt.
8. Security Measures
SPMS, E.P.E. is committed to ensuring the confidentiality and security of the personal data of CCNSNS users. To this end, SPMS, E.P.E. implements the necessary technical and organisational measures to protect said data against any form of improper or illegitimate processing and against any accidental loss or destruction. SPMS, E.P.E. creates and updates procedures to prevent unauthorized access and accidental stones and/or destruction of personal data.
9. Updating the Privacy Policy
This privacy policy, which is recommended to be carefully read, may be changed or updated at any time.
Such changes or updates will be published by SPMS, E.P.E. on the SNS 24 website, with express mention of the update date.
Changes of a more significant nature may also be notified by other means before their entry into force.
10. Use of the SNS website 24
10.1 Copyright and Intellectual Property
The content of the SNS 24 website is subject to copyright and related rights, as well as industrial property rights. As such, such content may not be used outside the conditions laid down in the legislation in force.
The user may copy, import or use national information or symbols on the website free of charge, for personal or public use, provided that such use is not for profit or potentially offensive purposes. The user must, however, expressly mention the source of the information.
Any attempts to alter or upload information or other actions that may affect the integrity of the system are prohibited.
10.2 Disclaimer
All information made available through the SNS 24 website, including text, treatments, dosages, results, graphics, images, videos or advice, is for informational purposes only and does not constitute individualized medical advice or allow any contractual relationship of responsibility to be established.
Considering the frequent changes in medical information, the clarifications contained in the SNS 24 website should not be considered complete or exhaustive, nor should they serve as a basis for carrying out treatments or recommending them to any individual.
If you want to obtain individualised medical advice, you should go to an NHS health service or, in case of emergency, call 112.
Jurisdiction
For the resolution of any disputes arising from the interpretation or application of this privacy policy, the parties elect as competent, as an express waiver of any other, the jurisdiction of the District of Lisbon.
(1) In this context, data relating to your health will only be processed by or under the responsibility of professionals who are bound by confidentiality, to the extent strictly necessary for the provision of care.
(2) Your data may, for example, be communicated to INEM, the Poison Information Centre or the Urgent Patients Guidance Centre for the purpose of triggering emergency means, and also to the Directorate-General for Health and healthcare providers, for the purposes of public health response and referral.
This policy was last updated on June 14, 2021