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GDPR · Medical & dental practices
⚠ Special category (Art. 9)

GDPR for medical & dental practices.
Your patients' health data is on WhatsApp.

Health data is a special category under Article 9 — the single highest-risk data an SME can hold, with the highest level of protection in the GDPR. Yet most practices exchange results, prescriptions and clinical images over WhatsApp and store X-rays on personal phones — convenient, and a textbook special-category breach waiting to happen.

€20M
or 4% turnover — max fine
72h
to report a breach (a lost phone counts)
Art. 9
health data = special category
Explicit
safeguards required by law

What most practices
are getting wrong.

None of this is malicious — it's just how the day flows. But with health data each one is a special-category gap a patient, a competitor or a disgruntled ex-employee can report, and the severity is high.

📱

Results & prescriptions over WhatsApp

Test results, prescriptions and clinical images sent to patients by WhatsApp. They land on personal phones, in cloud chat backups, with no encryption, access control or deletion.

🦷

X-rays & clinical photos on personal phones

Dentists and clinicians take X-rays and before/after photos on personal phones that sync to private photo libraries — special-category data outside any control.

🔑

Shared logins to the clinical software

The whole team uses one shared login to the practice-management or clinical software, so there's no individual accountability and no real audit trail of who saw which record.

🖥️

Screens & paperwork visible to others

Reception screens, open records and paperwork on the desk are visible to the next patient in the queue — casual disclosure of someone else's health data.

📣

Recalls & marketing with no consent

Recall reminders and promotional messages go out mixed together with no valid consent or opt-out, treating clinical contact and marketing as the same thing.

🔗

No DPA with software & labs

Patient data is passed to practice-management software, dental/medical labs and radiology providers with no data-processing agreement and no idea where it's stored.

⚠️

It only takes one. A lost phone, a forwarded image, a synced photo library — with health data any of these is a high-severity breach that is likely notifiable to the affected patients themselves, not just the authority. The fix is far cheaper than the incident.

How we make your
practice compliant — for real.

We don't hand you a policy and leave. We change how health data actually flows through your practice, with tools your team will actually use.

📥

Secure patient messaging / portal

An encrypted patient-messaging channel or portal for results, prescriptions and images — replacing WhatsApp and personal email — that staff and patients find easier, not harder.

Confirm the Art. 9 condition

We identify and document the correct Article 9 lawful condition for each use of health data (provision of care, explicit consent), on top of the Article 6 basis.

🔒

Access control + MFA + individual logins

Individual logins for every staff member, multi-factor authentication and proper access levels with audit logs — no more one shared login for the whole team.

🔐

Encryption of records & images

Patient records, X-rays and clinical photos encrypted at rest and in transit, kept off personal phones and private photo libraries.

📣

Consent for recalls & marketing

Clinical recalls separated from marketing, with a clean, documented consent and a working opt-out for promotions, offers and newsletters.

📄

DPAs, training & breach plan

Data-processing agreements with your software, labs and radiology providers, a short staff briefing and a simple breach procedure (including "I lost my phone").

A path that fits
how practices actually work.

01

Data-flow audit

We follow real patient data end-to-end: where the result, the X-ray and the prescription go, and on which device or tool.

02

Gap analysis

We flag the non-compliant flows and the concrete risks — prioritised, in plain language, not a 90-page report.

03

Remediation

We set up secure messaging, encryption, access control, consent and the DPAs — and migrate you off WhatsApp and personal phones.

04

Train & document

A short team briefing, a breach plan and the records of processing — so it stays compliant day to day.

← All GDPR sectors

GDPR for medical & dental
practices, answered.

The questions practices ask us most.

Can we message patients on WhatsApp?+
Not for health data. Results, prescriptions and clinical images sent over WhatsApp end up on a personal phone, in chat backups, outside any access control or retention policy. Health data is a special category under Article 9, so a leak is high severity and usually notifiable to the patients themselves. You need a secure patient-messaging channel or portal instead, with a clear lawful condition for the contact.
What makes health data "special category" (Art. 9), and what does it require?+
Article 9 treats data about a person's health — including dental and clinical data — as a special category that is prohibited from processing unless a specific condition applies, typically explicit consent or provision of health care by a professional bound by confidentiality. On top of an Article 6 basis, you must identify and document that Article 9 condition, apply stronger safeguards (encryption, strict access control, confidentiality), and treat any breach as high severity.
Do we need consent for recall reminders?+
It depends on the purpose. A clinical recall tied to ongoing care can often rest on the care relationship, but marketing — promotions, offers, newsletters — needs consent, with an opt-in and a working opt-out. Trouble starts when the two are mixed. We separate clinical recalls from marketing and document a clean consent and opt-out for each.
Do we need agreements with our clinical software and labs?+
Yes. Your practice-management software, dental and medical labs, radiology providers, email and cloud backup all process patient health data on your behalf, so you need a data-processing agreement (DPA) with each and must know where data is stored. With special-category data the supply chain is part of your compliance — we review your stack and put the right agreements and safeguards in place.
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