Privacy policy

Phone: +49 (0) 661/90190010
Fax: +49 (0) 661/90191590

Foreword

We, Healthcare Services & Solutions Consulting GmbH (hereinafter: “the company”, “we” or “us”) take the protection of your personal data seriously and would like to take this opportunity to inform you about data protection in our company.

As part of our responsibility under data protection law, additional obligations have been imposed on us by the entry into force of the EU General Data Protection Regulation (Regulation (EU) 2016/679; hereinafter: “GDPR”) in order to ensure the protection of personal data of the person affected by processing (we also refer to you as the data subject at “customer”, “user”, “you”, “you” or “data subject” ).

Insofar as we decide either alone or jointly with others on the purposes and means of data processing, this includes above all the obligation to inform you transparently about the type, scope, purpose, duration and legal basis of the processing (cf. Art. 13 and 14 GDPR). With this declaration (hereinafter: “Data protection information”) we inform you about the way in which your personal data is processed by us.

Our data protection information has a modular structure. They consist of a general part for any processing of personal data and processing situations that occur each time a website is accessed (A. General) and a special part, the content of which relates only to the processing situation specified there with the designation of the respective offer or product, in particular the visit to websites described in more detail here (B. Visit to websites).

In order to find the parts relevant to you, please refer to the following overview of the subdivision of the data protection information:

Part Designation This part is for you…
Part A General …always relevant.
Part B Website and social media presence …relevant if you use our German website, including our social media presence.

A. General information

1.  Definitions

Following the example of Art. 4 GDPR, this data protection notice is based on the following definitions:

– “Personal data” (Art. 4 No. 1 GDPR) means any information relating to an identified or identifiable natural person (“data subject”). A person is identifiable if they can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier, location data or by means of information relating to their physical, physiological, genetic, mental, economic, cultural or social identity characteristics. Identifiability can also be achieved by linking such information or other additional knowledge. The origin, form or embodiment of the information is irrelevant (photos, video or audio recordings may also contain personal data).

– “Processing” (Art. 4 No. 2 GDPR) means any operation which involves handling personal data, whether or not by automated means (i.e. using technical procedures). This includes in particular the collection (i.e. procurement), recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure or destruction of personal data, or alteration of the purposes for which they were originally processed.

– “Controller” (Art. 4 No. 7 GDPR) means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

– “Third party” (Art. 4 No. 10 GDPR) means any natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data; this also includes other legal entities belonging to the group.

– “Processor” (Art. 4 No. 8 GDPR) is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller, in particular in accordance with the controller’s instructions (e.g. IT service provider). In particular, a processor is not a third party in terms of data protection law.

– “Consent” (Art. 4 No. 11 GDPR) of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2.  Name and address of the controller

We are the controller responsible for the processing of your personal data within the meaning of Art. 4 No. 7 GDPR:

Healthcare Services & Solutions GmbH, represented by the managing directors Dr. Manfred Rolf Ziegler and Thorsten Uwe Zebisch

Königstraße 21, 70173 Stuttgart

Tel: +049 661/2500530

info@care-recruit.de

For further information about our company, please refer to the imprint information on our website www.hss-consult/impressum

3. legal bases of data processing

In principle, any processing of personal data is prohibited by law and is only permitted if the data processing falls under one of the following justifications:

–  Art. 6 para. 1 p. 1 lit. a GDPR (“consent”): Where the data subject has voluntarily, in an informed and unambiguous manner, indicated by a statement or other unambiguous affirmative act that he or she consents to the processing of personal data relating to him or her for one or more specific purposes;

–  Art. 6 para. 1 p. 1 lit. b GDPR: If the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;

–  Art. 6 para. 1 p. 1 lit. c GDPR: If processing is necessary for compliance with a legal obligation to which the controller is subject (e.g. a legal obligation to retain data);

–  Art. 6 para. 1 p. 1 lit. d GDPR: Where processing is necessary in order to protect the vital interests of the data subject or of another natural person;

–  Art. 6 para. 1 p. 1 lit. e GDPR: If the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, or

–  Art. 6 para. 1 p. 1 lit. f GDPR (“legitimate interests”): Where processing is necessary for the purposes of the legitimate (in particular legal or economic) interests pursued by the controller or by a third party, except where such interests are overridden by the interests or rights of the data subject which require protection of personal data (in particular where the data subject is a minor). 

The storage of information in the end user’s terminal equipment or access to information that is already stored in the terminal equipment is only permitted if it is covered by one of the following justifications:

–  § 25 para. 1 TTDSG: If the end user has consented on the basis of clear and comprehensive information. The consent has acc. Art. 6 para. 1 p. 1 lit. a DS-GVO to be carried out;

–  § 25 para. 2 No. 1 TTDSG: If the sole purpose is to carry out the transmission of a communication via a public telecommunications network or

–  § 25 para. 2 No. 2 TTDSG: If the storage or access is absolutely necessary so that the provider of a telemedia service can provide a telemedia service expressly requested by the user.

For the processing operations we carry out, we indicate the applicable legal basis in each case below. Processing can also be based on several legal bases.

4. data deletion and storage duration

For the processing operations carried out by us, we indicate below how long the data is stored by us and when it is deleted or blocked. Unless an explicit storage period is specified below, your personal data will be deleted or blocked as soon as the purpose or legal basis for storage no longer applies. Your data will only be stored on our servers in Germany, subject to any disclosure in accordance with the provisions in A.(6) and A.(7).

However, data may be stored beyond the specified period in the event of an (impending) legal dispute with you or other legal proceedings or if storage is provided for by statutory provisions to which we are subject as the controller (e.g. Section 257 HGB, Section 147 AO). If the storage period prescribed by the statutory provisions expires, the personal data will be blocked or deleted unless further storage by us is necessary and there is a legal basis for this.

5. data security

We use appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or against unauthorized access by third parties (e.g. TSL encryption for our website), taking into account the state of the art, the implementation costs and the nature, scope, context and purpose of the processing as well as the existing risks of a data breach (including its probability and impact) for the data subject. Our security measures are continuously improved in line with technological developments.

We will be happy to provide you with more detailed information on request.

6. cooperation with processors

As with any large company, we also use external domestic and foreign service providers to handle our business transactions (e.g. for IT, logistics, telecommunications, sales and marketing). They will only act in accordance with our instructions and have been contractually obliged to comply with data protection regulations in accordance with Art. 28 GDPR.

7. requirements for the transfer of personal data to third countries

As part of our business relationships, your personal data may be passed on or disclosed to third-party companies. These may also be located outside the European Economic Area (EEA), i.e. in third countries. Such processing is carried out exclusively for the fulfillment of contractual and business obligations and to maintain your business relationship with us (legal basis is Art. 6 para. 1 lit. b or lit. f in each case in conjunction with Art. 44 ff. GDPR). We will inform you about the respective details of the transfer at the relevant points below.

The European Commission certifies that some third countries have data protection standards comparable to the EEA standard by means of so-called adequacy decisions (a list of these countries and a copy of the adequacy decisions can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en). However, in other third countries to which personal data may be transferred, there may not be a consistently high level of data protection due to a lack of legal provisions. Where this is the case, we ensure that data protection is adequately guaranteed. This is possible via binding corporate rules, standard contractual clauses of the European Commission for the protection of personal data in accordance with Art. 6 para. 1 lit. a GDPR. Art. 46 para. 1 , 2 lit. c GDPR (the standard contractual clauses of 2021 are available at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32021D0915&locale-en), certificates or recognized codes of conduct. Please contact our data protection officer (see under A.(3)) if you would like more information on this.

8. no automated decision-making (including profiling)

We do not intend to use personal data collected from you for automated decision-making (including profiling).

9. no obligation to provide personal data

We do not make the conclusion of contracts with us dependent on you providing us with personal data beforehand. As a customer, you are under no legal or contractual obligation to provide us with your personal data; however, we may only be able to provide certain services to a limited extent or not at all if you do not provide the necessary data. If this should exceptionally be the case within the scope of the products presented below and offered by us, you will be informed of this separately.

10. legal obligation to transmit certain data

We may be subject to a special legal or statutory obligation to provide the lawfully processed personal data to third parties, in particular public authorities (Art. 6 para. 1 sentence 1 lit. c GDPR).

11. your rights

You can assert your rights as a data subject with regard to your processed personal data at any time by contacting us using the contact details provided at the beginning under A.(2). As the data subject, you have the right to

– to request information about your data processed by us in accordance with Art. 15 GDPR. In particular, you can request information about the processing purposes, the category of data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right to lodge a complaint, the origin of your data if it was not collected by us, and the existence of automated decision-making including profiling and, if applicable, meaningful information about its details;

– in accordance with Art. 16 GDPR, to immediately request the correction of incorrect data or the completion of your data stored by us;

– in accordance with Art. 17 GDPR, to demand the deletion of your data stored by us, unless the processing is necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims;

– in accordance with Art. 18 GDPR, to demand the restriction of the processing of your data if the accuracy of the data is disputed by you or the processing is unlawful;

– in accordance with Art. 20 GDPR, to receive your data that you have provided to us in a structured, commonly used and machine-readable format or to request that it be transferred to another controller (“data portability”);

– to object to the processing pursuant to Art. 21 GDPR, provided that the processing is based on Art. 6 para. 1 p. 1 lit. e or lit. f GDPR takes place. This is particularly the case if the processing is not necessary for the performance of a contract with you. If it is not an objection to direct advertising, we ask you to explain the reasons why we should not process your data as we have done when exercising such an objection. In the event of your justified objection, we will examine the situation and either discontinue or adapt the data processing or point out to you our compelling reasons worthy of protection on the basis of which we will continue the processing;

– pursuant to Art. 7 para. 3 GDPR, you have the right to withdraw your consent once given to us at any time (even before the GDPR came into force, i.e. before May 25, 2018) – i.e. your voluntary, informed and unequivocal consent to the processing of the personal data concerned for one or more specific purposes by means of a declaration or other unambiguous confirmatory act – if you have given such consent. As a result, we may no longer continue the data processing that was based on this consent in the future and

– in accordance with Art. 77 GDPR, to complain to a data protection supervisory authority about the processing of your personal data in our company, for example to the data protection supervisory authority responsible for us: The State Commissioner for Data Protection and Freedom of Information Baden-Württemberg, Lautenschlagerstraße 20, 70173 Stuttgart, e-mail: poststelle@lfdi.bwl.de, phone: 0711-615541-0, fax: 0711-615541-15

12. changes to the data protection information

As part of the ongoing development of data protection law and technological or organizational changes, our data protection information is regularly reviewed to determine whether it needs to be adapted or supplemented. You will be informed of any changes in particular on our German website at www.hss-consult.de . This data protection notice is valid as of May 2023.

B. Visiting websites

(1) Explanation of the function

Information about our company and the services we offer can be found in particular at www.hss-consult.de together with the associated subpages (hereinafter jointly referred to as “websites”). When you visit our website, your personal data may be processed.

(2) Processed personal data

We collect, store and process the following categories of personal data when you use the website for information purposes:

“Log data”: When you visit our websites, a so-called log data record (so-called server log files) is temporarily and anonymously stored on our web server. This consists of:

– the page from which the page was requested (so-called referrer URL)

– the name and URL of the requested page

– the date and time of the call

– the description of the type, language and version of the web browser used

– the IP address of the requesting computer, which is shortened so that a personal reference can no longer be established

– the amount of data transferred

– the operating system

– the message whether the call was successful (access status/Http status code)

– the GMT time zone difference

“Contact form data”: When contact forms are used, the data transmitted through them is processed (e.g. gender, surname and first name, address, company, e-mail address and the time of transmission).

(3)  Purpose and legal basis of data processing

We process the personal data specified above in accordance with the provisions of the GDPR, the other relevant data protection regulations and only to the extent necessary. Insofar as the processing of personal data is based on Art. 6 para. 1 p. 1 lit. f GDPR, the aforementioned purposes also constitute our legitimate interests.

The processing of log data serves statistical purposes and to improve the quality of our website, in particular the stability and security of the connection (legal basis is Art. 6 para. 1 sentence 1 lit. a or lit. f GDPR).

The processing of contact form data is carried out to process customer inquiries (legal basis is Art. 6 para. 1 sentence 1 lit. b or lit. f GDPR).

 If the processing of the data requires the storage of information in your terminal equipment or access to information that is already stored in the terminal equipment, § 25 para. 1 , 2 TTDSG provides the legal basis for this.

(4)  Duration of data processing

Your data will only be processed for as long as is necessary to achieve the above-mentioned processing purposes; the legal bases specified in the context of the processing purposes apply accordingly. With regard to the use and storage duration of cookies, please refer to point A.(4).

Third parties used by us will store your data on their system for as long as is necessary in connection with the provision of the services for us in accordance with the respective order.

You can find more details on the storage period under A.(4).

(5)  Transfer of personal data to third parties; basis for justification

The following categories of recipients, which are usually processors (see A.(6)), may have access to your personal data:

– Service providers for the operation of our website and the processing of data stored or transmitted by the systems (e.g. for data center services, payment processing, IT security). The legal basis for the transfer is then Art. 6 para. 1 p. 1 lit. b or lit. f GDPR, unless they are processors;

– Government agencies/authorities, insofar as this is necessary to fulfill a legal obligation. The legal basis for the transfer is then Art. 6 para. 1 p. 1 lit. c GDPR;

– Persons engaged to carry out our business operations (e.g. auditors, banks, insurance companies, legal advisors, supervisory authorities, parties involved in company acquisitions or the establishment of joint ventures). The legal basis for the transfer is then Art. 6 para. 1 p. 1 lit. b or lit. f GDPR.

For guarantees of an adequate level of data protection when data is transferred to third countries, see A.(7). 

In addition, we will only pass on your personal data to third parties if you have given your consent in accordance with Art. 6 para. 1 p. 1 lit. a GDPR have given their express consent to this.

(6) Use of cookies, plugins and other services on our website

a) Cookie

We use cookies on our websites. Cookies are small text files that are assigned to the browser you are using and stored on your hard disk by means of a characteristic string of characters and through which certain information flows to the site that sets the cookie. Cookies cannot run programs or transfer viruses to your computer and therefore cannot cause any damage. They serve to make the website more user-friendly and effective overall, i.e. more pleasant for you.

Cookies may contain data that make it possible to recognize the device used. In some cases, however, cookies only contain information on certain settings that are not personally identifiable. However, cookies cannot directly identify a user. 

A distinction is made between session cookies, which are deleted as soon as you close your browser, and permanent cookies, which are stored beyond the individual session. With regard to their function, a distinction is made between cookies:

– Technical cookies: These are strictly necessary to move around the website, use basic functions and ensure the security of the website; they do not collect information about you for marketing purposes or store which websites you have visited;

– Performance cookies: These collect information about how you use our website, which pages you visit and, for example, whether errors occur when using the website; they do not collect any information that could identify you – all information collected is anonymous and is only used to improve our website and to find out what interests our users;

The legal basis for cookies that are absolutely necessary to provide you with the expressly requested service is § 25 para. 2 No. 2 TTDSG. Any use of cookies that is not technically necessary for this purpose constitutes data processing that can only be carried out with your express and active consent in accordance with Art. 6 para. 1 lit. f GDPR. § 25 para. 1 TTDSG in conjunction with Art. 6 para. 1 p. 1 lit. a GDPR is permitted. This applies in particular to the use of performance, advertising, targeting or sharing cookies. In addition, we will only pass on your personal data processed by cookies to third parties if you have given your consent in accordance with Art. 6 para. 1 p. 1 lit. a GDPR have given their express consent to this.

b) Plugins

We use WordPress OMGF as a plugin on our websites. This means that Google Fonts are integrated locally on our websites. Google Fonts are fonts that are provided by Google. If these are not integrated locally, but are loaded by Google every time you visit our websites, the personal data of website visitors is processed by Google in the USA. The WordPress OMGF plugin avoids this processing in third countries. Your personal data is not processed through the use of the plugin.

c) Social media plugins

We do not use any social media plugins on our websites. If our websites contain symbols from social media providers (e.g. LinkedIn), we only use these to passively link to the pages of the respective providers.

Data protection information version May 2023