Once every three months I send all my clients via email a link to a questionnaire where they can evaluate my care anonymously.
If you don’t want to wait for that email, or if you can’t find it anymore, then you can use this link.
As a client it is good to know the way the lactation consultant IBCLC handles your personal data. The lactation consultant IBCLC needs to be able to prove that the way she processes complies with the most important principles of processing. Such as legitimacy, transparency, purpose and accuracy (accountability).
As of May 25 2018 the Algemene verordening gegevensbescherming (AVG) or General Data Protection Regulation (GDPR) became law. This means that the same privacy laws are effective in all of the European Union (EU). The Wet Bescherming Persoonsgegevens (WBP) as part of the Dutch legislation no longer applies. Besides this general law specific rules for privacy protection apply for healthcare workers. These rules are stated in the Wet op de geneeskundige behandelingsovereenkomst (WGBO).
Processing personal data
Personal data are all data that can lead back to a person. The lactation consultant IBCLC is required to obtain permission to process personal data and she needs data to be able to execute the agreement. She can only ask data that are required to help you adequately. The data have to be appropriately protected. This way she complies with the basics for processing personal data. A lactation consultant in private practice does not have a data protection officer.
The purpose of reporting is:
- registration of care delivered;
- reference for the lactation consultant or her replacement to give responsible care;
- accountability for care given;
- opportunity to financially settle given care.
The following information will be included in the report:
- personal data/ identification data
- financial and administrative data
- lactation/psychological and medical data.
Right to review your data
You are entitled to inspect any data about yourself that is kept by the lactation consultant. If you feel that your data is incorrect or inaccurate, you can request your lactation consultant IBCLC to change the data (correction) or to remove it (right to forget). Your data will be kept confidential to unauthorized persons and persons who do not need to process this data. You have the right to receive this data (right to data portability). When you object to me recording your data you can inform me about that.
DPIA = Data Protection Impact Assessment
In virtue of the Algemene Verordening Gegevensbescherming (AVG) all organisations need to make a DPIA when the processing of personal data probably has a high risk for the rights and freedom of natural persons whose data are being processed. The work of a lactation consultant does not constitute a high risk.
Contact with other healthcare workers
Whenever the lactation consultant needs to send the report or a transfer document to another healthcare worker consent needs to be given. Verbal consent is sufficient, this will be recorded in the report.
The lactation consultant can only contact others without consent when she has serious concerns about mother and/or her child.
Privacy by design of default
The lactation consultant will take the protection of privacy sensitive information into account when designing new products. She only processes information that is necessary for a specific purpose.
Information will not be given to third parties without consent, not even to close family members. As client you need to give permission. The lactation consultant IBCLC, given the nature of her work, has to comply to the law on Medisch Beroepsgeheim. In IBLCE’s Code of Personal Conduct professional confidentiality is stated as a requirement and it is mandatory for lactation consultants to comply to this.
Before a lactation consultant decides it is necessary to break confidentiality she first has to assess if breaking confidentiality by informing other professionals will help solve the issue. In extreme situations the lactation consultant IBCLC can consider to turn to judicial institutions.
SSL-certificate website (Secure Socket Layer)
An SSL-certificate secures the connection between the visitor and the website. The data that goes through this connection, will be encrypted and is not readable for others. The green padlock or the green address bar show visitors and clients clearly that the website is secure. Whenever it is possible to fill out contact information on the website, an SSL- certificate is mandatory.
On basis of the Wet op de Geneeskundige Behandelingsovereenkomst (WGBO) healthcare workers are required to keep files. The retention period is 15 years.
A data leak is the unintended access or destruction, alteration or leaking of personal data from an organization. Not just the leaking of data is considered a data leak, it can also mean the unauthorized processing of information. A lactation consultant has the duty to report any data leaks to the authority personal data.
When, in your opinion, the lactation consultant IBCLC hasn’t handled your personal data in an appropriate manner, your first step should be to inform her of this. When you consider to file a complaint we refer you to the website of Nederlandse Vereniging van Lactatiekundigen for more information on our complaints committee. For more information see Complaints section at the end of this page.
The full title of the WHO code is ‘International Code of Marketing of Breast-Milk Substitutes’. This code is written to regulate the marketing of infant feeding products and applies to infant formula, follow-on formula, other food products for infants younger than four months, like juice, tea and fruit and also to bottles and teats.
The goal of the code is that parents can decide how to feed their child without being influenced by commercial companies. Due to the WHO-code the marketing of breast-milk substitutes for infants younger than six months is restricted in the Netherlands. The WHO-code is broader than the Dutch Commodities Act or European laws and regulations.
I endorse the WHO-code but I don’t just work with brands and products of companies that comply with the WHO-code. This is the reason why I will not promote certain brands.
The intention of the WHO-code is:
- to protect and enhance breastfeeding
- to sufficiently and correctly inform parents
- that breast-milk substitutes are used correctly when needed
- that regulations for the sale and marketing of infant foods are followed
You can read the full text of the WHO-code here
If you are not satisfied with my service or have a complaint about your contact with me, I appreciate it when you contact me directly about this. You can do so in writing, by phone or via an e-mail.
Because I am affiliated with the NVL you can also file your complaint with the Klachtencommissie: https://www.nvlborstvoeding.nl/ouders/klachtenprocedure/
The complaints officer with the NVL will mediate. If this doesn’t lead to a solution, the complaint will be assessed by the complaints committee, they will form an opinion/judgement whether or not the complaint is justified. If they find justification, the committee will propose individual measures or sanction to the board.
If this judgement by the complaints committee isn’t satisfactory to you, there is the option to turn to an arbitration board.
I meet the requirements of the Wet kwaliteit, klachten en geschillen zorg (WKKG).