Privacy Policy for Clients / Therapists

To ensure that you are fully informed about the processing of your personal data within the feedback process, please take note of the following information.

We would like to point out that personal data is processed as part of the PROMs collection, which may include particularly sensitive data.
It is our concern to make the collection and processing as anonymous as possible within the scope of the purpose.

Definitions

“Processing” means any operation related to personal data such as collecting, recording, organizing, structuring, storing, adapting, altering, retrieving, using, disclosing, transmitting, disseminating, archiving, deleting, or destroying.

As “personal data” (hereinafter referred to as “personal data”), all information and data relating to an identified or identifiable person are considered.

As “sensitive data”, information about racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, and genetic or biometric data are considered.

Contact Information

For questions or concerns regarding the protection of your data by us, you can reach us at any time via email at datenschutz@the-check.ch. Responsible for data processing is:

PROMS-CAM
c/o Swiss Osteopathic Association
Uferweg 15
3013 Bern
Switzerland

The software behind “The Check” is powered by Qualitouch.

Data Origin

The data originates from:

  • directly from the therapists during registration
  • directly from clients who voluntarily register and provide feedback via standardized questionnaires
  • from therapists who grant access to their clients
  • from technical system data when visiting the app or website (e.g., IP address, timestamp)

Data Categories

Specifically, the following are collected and processed:

Data from therapists:

  • Name, profession, registration number (e.g., EMR no.)
  • Practice address, contact details
  • Additional data collected by therapists

Data from clients:

  • Initials, optionally name, year of birth, gender
  • Optionally email address (optional, if login requested)
  • Health data (e.g., complaints, diagnoses)
  • Data related to feedback based on questionnaires (e.g., progress, self-assessment, complaints, restricted activities, mental well-being, specific feedback on therapy)
  • Additional data collected by clients
  • Usage data (e.g., time of feedback)
  • Login/Access data (encrypted)

Purpose of Data Processing

The feedback system serves for quality assurance and further development of therapeutic work. It enables clients to provide regular and structured feedback on therapy (e.g., via digital questionnaires).

The evaluation is carried out for reflection on the therapeutic process and for joint goal review between therapist and client. It supports continuous adaptation and improvement of the therapeutic relationship and working methods.

The platform processes exclusively anonymized data. The transfer of this anonymized data to third parties is possible, for example, in the context of research collaborations or for the further development of the platform. It is ensured that no conclusions can be drawn about affected individuals.

Furthermore, the results can be used in aggregated and anonymized form for internal quality assurance or external reporting – for example, in the context of project documentation or performance records. No conclusions can be drawn about individuals.

Recipients of Data

Only the assigned therapists have access to the feedback data. No data is transferred to third parties, except in anonymized form for research or evaluation purposes. No unanonymized data is transferred to third parties without explicit consent.

Under certain circumstances, we may rely on the services of third parties or affiliated companies and commission them with the processing of your data (so-called processors). Categories of recipients include:

  • Manufacturer of the software used
  • Accounting, fiduciary, and auditing firms;
  • Consulting firms (legal advice, taxes, etc.);
  • IT service providers (web hosting, support, cloud services, website design, etc.);
  • Payment service providers;

We ensure that these third parties and our affiliated companies comply with data protection requirements and treat your personal data confidentially.

Under special circumstances, we may be obliged to disclose personal data to authorities.

Automated Individual Decision-Making and Profiling

We do not use automated individual decision-making according to Art. 21 DPA. Likewise, we do not apply automated evaluation of personal data to assess, analyze, or predict certain personal aspects relating to a natural person (Profiling Art. 5 DPA).

Retention and Deletion

Feedback data is retained for the duration of the therapeutic relationship. After therapy completion, the collected data is retained for a maximum of 10 years and then completely deleted, provided no legal retention obligations exist. The retention is done in anonymized form.

Data Security

We implement technical and organizational security measures to protect your personal data against manipulation, loss, destruction, or unauthorized access. This includes, among other things, the use of
recognized encryption methods (e.g., encryption via SSL/TLS), multi-factor authentication, the use of firewalls, or extensive data backups. Our security measures are continuously improved in line with technological developments.

The data is exclusively stored and processed on servers in Switzerland. Hosting is provided by a Swiss provider who complies with applicable data protection regulations and ensures high security standards.

Your Rights

Regarding the processing of your personal data, you have the following rights against us under the legal conditions:

Right of Access

You can request confirmation at any time as to whether and which personal data concerning you is being processed. In this case, you have the right to information about the identity and contact details of the responsible person, the processed data as such, the purpose of processing, the retention period, the origin of the data, the recipients to whom the data is disclosed, and the existence of automated decision-making.

Right to Rectification

If your personal data is inaccurate or incomplete, you have the right to request its rectification.

Right to object

You have the right to object to the processing of your personal data at any time. It should be noted that the revocation only takes effect for the future. Processing that occurred before the revocation is not affected by it.

Right to Erasure

You can request the deletion of your data stored with us at any time. We will then immediately and irrevocably delete your personal data as soon as all existing contracts and other legal relationships with you have been fully settled and insofar as we are not legally obliged to retain your personal data or the processing serves the assertion, exercise, or defense of legal claims. Please note that after deletion, we will no longer be able to access the data you provided.

Right to Data Portability

You have the right to receive your personal data that you have provided to us in a structured and commonly used electronic format, and to transmit this data to another controller.

Consent and Withdrawal

By registering on the website and completing the digital questionnaire, clients and therapists expressly agree to the processing of their personal and health-related data in accordance with this Privacy Policy.

Consent is voluntary and can be withdrawn at any time with future effect. A withdrawal has no effect on processing already carried out lawfully.

Changes and Updates to the Privacy Policy

We ask you to regularly inform yourself about the content of our Privacy Policy. We may adapt this Privacy Policy at any time without prior notice as soon as changes in the data processing carried out by us make this necessary. The current version published on our website applies. You will not be informed separately.

Should any provision of this Privacy Policy be invalid, this shall not affect the validity of the remaining provisions. Invalid provisions shall be replaced by provisions that come closest to the intended meaning of the invalid provision.