Privacy Policy – POPIA & PAIA

1. Who we are (Responsible Party)

The responsible party for your personal information is Dr Anton Julyan Orthopaedic Surgeon Inc (Registration No 2006/020217/21; Practice No PR 0232408), a specialist orthopaedic practice at Suite 6, Netcare Pretoria East Hospital, Cnr Garsfontein Road & Netcare Drive, Moreletapark, Pretoria 0044.

Information Officer: Dr Anton Julyan. You may contact the Information Officer about this policy or your information by email at anton@antonjulyan.co.za or by phone on 012 998 7550.

2. The information we collect

Depending on your interaction with us, we may collect: your name and contact details; your date of birth and identity/passport number; your medical aid (scheme) name, plan and membership number; and health information — your symptoms, diagnoses, imaging and test results, treatment and surgical records, and related clinical correspondence. Under POPIA, health information is “special personal information” and is treated with additional care.

We collect this information directly from you (for example through the appointment form, at reception, or during consultation), and from your referring doctor, the hospital, medical scheme, pathology and radiology providers involved in your care.

3. Why we use your information

We process your information to: respond to appointment requests and enquiries; provide medical assessment, diagnosis, treatment and follow-up care; submit and administer medical scheme claims and obtain pre-authorisation; keep accurate medical records as required by law and the HPCSA; and communicate with other healthcare providers involved in your care. We do not sell your information, and we do not use it for advertising.

4. Consent and lawful basis

We process health information with your consent and/or because it is necessary for the provision of medical care by a health professional, as permitted under section 32 of POPIA. Where you submit the appointment form, you consent to us storing and using those details to contact you. You may withdraw consent for non-essential processing at any time, although this may affect our ability to provide care or administer your claims.

5. Who we share it with

We share information only as needed for your care and its administration, including with: the treating hospital (Netcare Pretoria East and, where relevant, CintoCare); your medical scheme and its administrators for authorisation and claims; referring and treating practitioners, anaesthetists, pathology and radiology providers; and our administrative service providers (“operators”) such as billing, IT and email providers, who are bound to protect your information and use it only on our instruction. We may also disclose information where required by law or a court order.

6. Cross-border processing

Some service providers (for example email or cloud hosting) may store data on servers outside South Africa. Where this happens, we take reasonable steps to ensure the information receives a comparable level of protection to that required by POPIA.

7. How we protect and keep your information

We apply reasonable technical and organisational safeguards to protect your information against loss, unauthorised access and misuse. We keep medical records for at least the period required by law and HPCSA guidelines — generally a minimum of six years from the date of last treatment, and longer where the law requires (for example, records of minors are kept until well after they reach majority).

8. Your rights under POPIA

You have the right to: ask what information we hold about you and request access to it; ask us to correct or update information that is inaccurate; object to processing in certain circumstances; and request deletion where the law allows. Clinical records that we are legally obliged to retain cannot be deleted on request. To exercise any of these rights, contact our Information Officer using the details in section 1.

9. PAIA – access to records

The practice’s manual under the Promotion of Access to Information Act (PAIA) sets out the records we hold and how to request access to them. A copy is available from the Information Officer on request.

10. Cookies and website analytics

This website is largely static and does not use tracking or advertising cookies. Certain embedded services (such as an embedded map or web fonts) may be provided by third parties who could receive limited technical data, such as your IP address, when a page loads. You can control cookies through your browser settings.

11. Complaints to the Information Regulator

If you believe we have not handled your information lawfully, you may lodge a complaint with the Information Regulator (South Africa): JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001. Email POPIAComplaints@inforegulator.org.za or enquiries@inforegulator.org.za; website inforegulator.org.za. We would appreciate the chance to resolve your concern first — please contact our Information Officer.