Privacy statement CM-Zorgkas

CM-Zorgkas respects your privacy in accordance with applicable legislation.

What is a processing of personal data? Some clarifying concepts

Personal data
All information about an identified or identifiable natural person ('the data subject') (i.e. not a company). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.

An operation or set of operations performed on personal data or on sets of personal data, whether or not carried out by automated means, such as collecting, recording, organizing, structuring, storing, updating or modifying, retrieving, consulting, using, providing by means forwarding, disseminating or otherwise making available, aligning or combining, blocking, erasing or destroying data.

A 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.

A natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Who processes your data?

Your personal data is processed by RMOB (Regional Mutual Assistance Company) CM-Zorgkas Vlaanderen, with registered office Haachtsesteenweg 579, 1031 Schaarbeek, Belgium and with company number 476.572.381.

For what purpose is CM-Zorgkas allowed to process your personal data?

Processing your personal data is necessary:

  • to identify you, contact you and advise you correctly;
  • for the management of your membership and your file in the context of Flemish social protection.

As a healthcare fund, CM-Zorgkas has the following main mission: 'The healthcare fund functions as a unique counter for Flemish social protection. The health fund collects the contribution, informs, processes the application, guarantees file follow-up, assesses whether the conditions have been met, decides and pays out in accordance with the Flemish social protection decree and the implementation decisions based on it.'

CM-Zorgkas puts Flemish social protection into practice and processes all necessary personal data to properly carry out the following main tasks and objectives:

  • Management of the members' health insurance premium.
  • For the insurability of members: management of your rights in the context of Flemish social protection.
  • Management of files in the context of Flemish social protection.
  • Management of disputes including disputes against the decisions of CM-Zorgkas, recoveries of undue payments, ...
  • Management of your contacts with CM-Zorgkas through any channel used: face to face, letter, telephone, text message, e-mail, chat, website, ...
  • The good management and improvement of our services and the Flemish social protection system, and for the fight against fraud.
  • Complying with our legal obligations.

Processing your personal data as a volunteer is necessary for the following purposes:

  • to be able to contact and communicate with the volunteer;
  • in order to be able to pay any expenses to the volunteer.

What are the legal provisions for the processing of your data in the context of Flemish social protection?

  • Decree of 18 May 2018 on Flemish social protection.
  • Decision of the Flemish Government regarding the implementation of the decree of 18 May 2018 on Flemish social protection.

How long does CM-Zorgkas store your data in the context of Flemish social protection?

CM-Zorgkas will store and use your personal data to the extent necessary for compliance with legal obligations and within the context of our assignments. In certain cases, CM-Zorgkas is bound by legal retention periods for storing certain personal data. If the law does not prescribe a period, the personal data can be kept for a period that CM-Zorgkas itself considers necessary for the efficient implementation of Flemish social protection.

For what purpose may CM-Zorgkas process your personal data in the context of data exchange, telephone conversations, camera surveillance and others?

Exchange of data with the Christian Mutuality (hereinafter: CM)

CM-Zorgkas exchanges data with CM to the extent necessary to carry out statutory tasks. These legal duties include:

  • the exchange of certain certificates (administrator, legal representative, imprisonment, collective debt settlement...)
  • the exchange of requests and billed services for mobility aids and wheelchair advice reports
  • the exchange of information about reimbursed services to the legal service in the context of recoveries.

Exchange with other entities or third parties subject to your consent
To the extent that you have given your permission for this, CM-Zorgkas exchanges data with universities, for example. This is to ensure that your file is processed more smoothly or for other purposes for which you have given your consent (participation in surveys, etc.).

Recording of chat and telephone conversations
In some cases, CM-Zorgkas can listen to and record the information via its telephone or chat conversations. This is to improve our services or in the context of providing evidence in the event of a dispute. You will always be informed about this in advance by a recorded message.
The retention period for telephone conversations is:

  • three months for training and coaching of employees and improvement of services;
  • eighteen months in the context of complaints.

The retention period for chat conversations is:

  • three months for training and coaching of employees and improvement of services;
  • 24 months in the context of complaints.

Camera surveillance
CM-Zorgkas can use cameras in and around the offices and buildings where it is active. When it comes to surveillance cameras, CM-Zorgkas respects the legal rules. The retention period for image recordings by surveillance cameras in and around the CM-Zorgkas buildings (indicated by a sticker) is:

  • maximum one year;
  • exception: this period can be extended if it appears that the images can be useful and have some evidentiary value for, for example, a crime.

Recruitment of new employees
There is a separate privacy policy for this.

Which personal data does CM-Zorgkas process about you?

Depending on the data you provide and the various objectives, CM-Zorgkas processes the following categories depending on the type of people involved.

Ordinary personal data

  • Identification data: name, first name, address, telephone number, e-mail address, ...
  • Electronic identification data: IP addresses, cookies, connection times, etc.
  • Personal characteristics: age, gender, date of birth, place of birth, marital status, nationality.
  • Composition of the family: name of partner, number of children, ...
  • Financial details: account number, payments, ...
  • Image recordings: camera surveillance, photos, videos.
  • Sound recording: call centers.

Special personal data

  • Data from the National Register and the national register number of members of CM-Zorgkas: surname, first name, official main residence, date of birth, date of death and place, gender, marital status, nationality, family composition.
  • Social data: data from the Crossroads Bank for Social Security or that are necessary for the implementation of Flemish social protection: history of employee contribution vouchers, unemployed, pension, affiliation, insurability, ...
  • Personal data relating to health are data that provide information about a person's health status: degree of need for assistance, medical diagnoses, ...
  • In the context of disputes, CM-Zorgkas will also process criminal and administrative convictions and criminal offenses: prison stays, fraud, legal measures, ...
  • In the context of scientific research, CM-Zorgkas can indirectly derive sensitive data from the data it processes, such as race, ethnic origin, political opinions, religious or philosophical beliefs, sexual behavior or sexual orientation.

From whom or from what source does CM-Zorgkas receive information about you?

This mainly concerns data that comes from:

  • from yourself, your legal representative or someone who has received a mandate or your approval for this;
  • from CM;
  • from the healthcare providers (hospitals, doctors, nurses, etc.) that you have consulted, including via the third-party payment scheme;
  • via the Crossroads Bank for Social Security of social security institutions and government services (Flemish Agency for Care and Health, Federal Public Service Finance, Federal Public Service Social Security, etc.).

Which employees process your personal data?

Your personal data is processed carefully and confidentially by the authorized employees to perform their tasks in the context of the described assignments. The employees are bound by professional secrecy and must comply with the duty of discretion. This is imposed legally (Crossroads Bank Act, National Register Act, Article 458 of the Criminal Code, Labor Code) and deontologically. In addition, CM-Zorgkas requires its employees to sign a confidentiality statement.

Certain data processing takes place in a fully automated manner without the intervention of an employee, but on the basis of the criteria determined in the context of Flemish social protection (e.g. calculation of the healthcare premium, compensations on healthcare budgets, etc.).

To whom does CM-Zorgkas pass on your personal data?

Your personal data may be passed on to:

  • yourself, your legal representative (administrator, etc.), your representative (lawyer, etc.) or someone who has received a mandate or your approval for this;
  • an authorized third party (person, institution, government) solely on the basis of a law, contract, existing authorization from a Sectoral Committee (Social Security, and Health, National Register);
  • CM, to the extent that the data exchange is necessary to comply with legal obligations;
  • government services (Flemish Agency for Care and Health, Federal Public Service Social Security, etc.);
  • municipal authorities with your permission;
  • social security institutions through the Crossroads Bank for Social Security;
  • our auditors who are bound by a duty of confidentiality;
  • counterparties, their lawyers, bailiffs, experts and to the Ministry of Justice in the event of disputes;
  • all institutions to grant you a benefit based on a privileged status, subject to your consent or authorization;
  • our processors: IT processors, mailing companies, our lawyers and bailiffs, experts.

In what other situations can CM-Zorgkas process your data?

Visit the CM website
If there is a form to be completed on the website, the data communicated will be processed depending on the context-specific purposes for which it was requested (e.g. request for information, registration for an activity, information about volunteer work).
What CM processes and the user does not see (e.g. your IP address, browser type, operating system of your computer and the number of visits and pages visited): see cookie policy .

I want to work for CM-Zorgkas
See separate privacy statement

I am a healthcare provider
In that case, CM-Zorgkas only processes personal data relating to your activities as a healthcare provider and this in the context of the objectives described above.

How is your data secured?

  • We take appropriate measures to ensure the security, integrity and availability of your data, taking into account the state of the art, the scope and context of the processing purposes and the type of personal data.
  • CM-Zorgkas takes appropriate physical, administrative, organizational and technical security measures to protect your personal data against loss, unauthorized access, unauthorized use and unauthorized disclosure.
  • CM-Zorgkas contractually imposes the same security measures on its processors.

What are your rights with regard to personal data?

The person concerned has certain rights with regard to his personal data insofar as these do not conflict with the legal obligations or the public interest tasks entrusted to CM-Zorgkas.

Right of access
As a data subject, you have the right to inspect the data relating to you that is processed by CM-Zorgkas. If you request this, a copy of your personal data can be provided.
You can request a copy of your personal data as long as this does not infringe the rights and freedoms of others.

Right to rectification or amendment of your data
You can request at any time to correct incorrect data or to complete your data.
To adjust your data regarding your marital status, please contact the population department of your municipality in the first place. However, CM-Zorgkas cannot change the data of the national register, which is the authentic source of social security.
Please remember to inform us as soon as possible of any change in your situation.

Withdraw your consent
If the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time without providing a reason. Withdrawing your consent does not change the validity of the processing that took place before that withdrawal.

Automated individual decision-making (profiling)
You have the right not to be subject solely to automated decision-making, including profiling. After all, some data processing is completely automated without the intervention of the employee.
If you do not agree with the course of a fully automated process, you can contact CM-Zorgkas. For example, you can request intervention from a CM-Zorgkas employee or let us know why you dispute this.

Right to object
If you do not agree with the way CM-Zorgkas processes certain data, you can object to it.

  • If your data is processed in the context of a task carried out in the public interest, you must provide reasons related to your specific situation. However, CM-Zorgkas may still process this data if there are compelling legitimate reasons for the processing that take precedence over your interests or the exercise of a legal claim.
  • If your data is processed for scientific or historical research purposes or for statistical purposes, you can object on grounds relating to your particular situation, unless the processing is necessary to fulfill a task carried out for reasons of public interest.

Right to erasure (right to be forgotten)
You have the right to delete your personal data if it appears that CM-Zorgkas is processing this data unlawfully:

  • if the data is no longer necessary for the purposes of the treatment;
  • if you have withdrawn your consent and there is no other legal basis for this treatment;
  • if your objection to the processing is well-founded;
  • if the treatment is illegal;
  • if erasure is required by law;
  • if the data relates to a child under the age of 16 and is collected via an application or website (Information Society Service).

Right to restriction of processing
You can limit the use of your personal data:

  • until the time to check the accuracy of the data you dispute;
  • if you object to the illegal deletion of data processed by CM-Zorgkas;
  • if you object to the deletion of data that CM-Zorgkas no longer needs, but which are necessary to establish, exercise or defend a right in court;
  • until the time to check whether the legitimate reasons for CM-Zorgkas take precedence over yours in case you object to the treatment of this data by citing your specific situation.

CM-Zorgkas will then have to limit the processing of such personal data to their storage. Any other processing is permitted with your consent, or for the establishment, exercise or defense of a right in legal proceedings or to protect a third party, or for important reasons of public interest. If this is the case, CM-Zorgkas will inform you before this restrictive treatment is lifted.

Right to data portability
You have the right to have the personal data you have provided to CM-Zorgkas transferred directly to you or to a third party. This is possible insofar as it is not limited by privacy legislation or other legal rules. However, this right can only be exercised if your data has been processed solely on the basis of your consent or a contract, and if this processing is done using automated processes.
However, in the event of a change, CM-Zorgkas sends the information that it is legally obliged to forward to the new insurer.

How can you exercise your rights?

If you wish to exercise any of the above privacy rights, you can always contact us.

Always be as specific as possible if you want to exercise your rights. Only in this way can CM-Zorgkas handle your question specifically and correctly. To ensure that the data subject wishes to exercise his own privacy rights, CM-Zorgkas may request a copy of the identity card for identification purposes.

How can you contact us or file a complaint?

You can always contact us with a question, comment or request to exercise your rights:

  • by letter to CM-Zorgkas, Haachtsesteenweg 579, 1031 Schaarbeek, Belgium;
  • by e-mail: [email protected];
  • by telephone: 078 15 40 40 (CM-Zorgkas call center).

Data protection officer
If you feel that the above channels cannot help you, you can also contact our data protection officer. This can be either:

  • by sending a letter to CM-Zorgkas, Attn. data protection officer, Haachtsesteenweg 579, 1031 Schaarbeek, Belgium;
  • by email to [email protected] .

Data Protection Authority
In addition to the option of contacting us directly, you also have the option of contacting the Data Protection Authority (formerly: Privacy Commission): Commission for the Protection of Privacy, Drukpersstraat 35, 1000 Brussels, /nl/contact .