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European Privacy Seal for Siemens Healthcare GmbH

Product/Version

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teamplay

Connect, compare, collaborate.

teamplay service as provided to EU customers

Function as provided in August 2016

Qualification: IT-based service

View the teamplay certificate

Cert. No.

EP-S-LY0CS3

Validity

07/10/2016 - 31/10/2018

Monitoring

06/2017 (O.K.)

02/2018 (O.K.)

Public Report

teamplay Short Public Report Image   

Manufacturer/Provider

Siemens Healthcare GmbH

Henkestr. 127
91052 Erlangen
Germany

BEST

The teamplay receiver removes data types that could be used for (re-)identification of patients completely or replaces them by a pseudonym or a less precise value such as an age range in a reliable manner. The extent of the de-idenficiation depends on the privacy profile that is chosen by the user, with the strictest of these providing for true anonymization of patient data. Thus, teamplay lives up to the principle of data minimization in an exemplary manner.

Comprehensive, intelligible and up-to-date documentation is in place which informs the teamplay users about their responsibilities as controllers when it comes to the processing of personal data. 

ATTENTION

Regarding the processing of patient data, it must be highlighted that users of teamplay qualify as controllers whereas Siemens Healthcare GmbH acts as a processor on behalf of the users. Customers are advised that - depending on the chosen privacy profile - the legitimate use of the service may require the collection of patients' consent and release from medical confidentiality. More detailed information on this topic is available below at "Details" as well as in the Short Public Report.

SUMMARY

Siemens Healthcare GmbH provides the cloud-based service teamplay that can be accessed via https://teamplay.siemens.com. The service is offered to hospitals and other medical facilities making use of devices for medical imaging (e.g., computer tomography (CT) or magnetic resonance imaging (MRI) devices). It enables the users of devices for medical imaging to monitor the efficiency of the utilization of these devices as well as the radiation dose consumption. This way they can improve their image acquisition procedures and identify radiation doses which are as low as reasonably achievable to meet clinical needs. teamplay consists of web-based services which are deployed as a cloud service on the teamplay platform, and a software-only gateway ("teamplay receiver") to be installed in, e.g., a hospital network. The teamplay receiver acts as an intermediary between the hospital computer systems and the web-based services.

In respect of the amount of patient data to be processed, Siemens Healthcare GmbH provides different options to the users of the service. If the user chooses the strictest of the preconfigured settings of the service ("privacy profiles"), then only anonymous data is processed by teamplay. When one of the two remaining privacy profiles is chosen, patient data is de-identified, but still constitutes personal data.  

DETAILS

teamplay is offered as a basic and as a premium account. It is worth noting that the premium account encompasses all functionalities of the basic account. The target of evaluation of the teamplay certification is the premium account as it is provided to EU customers. More precisely, the ToE consists of the following modules / components of said premium account:

  • The modules "usage", "dose" and "protocols" (cf. the Short Public Report for details);
  • the "teamplay receiver" (software to be installed in the IT environment of the users of the service);
  • the web based services that allow for the use of the modules "usage", "dose" and "protocols";
  • legal and technical interfaces with the sub-processors Microsoft Ireland Operations Ltd. and Siemens Healthcare Private Limited (India).

Excluded from the target of evaluation is teamplay as it is offered to the US market or to other markets outside of the EU / European Economic Area (EEA). In addition, the following modules / components of teamplay as it is provided to EU customers do not form part of the ToE either:

  • The module "images" which allows for the collaborative use of data and images as well as for the establishment of an online community;
  • authentication of users via the Siemens Corporate Authorization Service that provides an alternative login functionality for teamplay;
  • the Microsoft Azure Cloud as such (including components of the data centres that are used for the provision of the teamplay service to EU customers);
  • the IT environment of the teamplay users.

When providing the teamplay service, Siemens Healthcare acts as a processor on behalf of the users of the service. This means that the responsibility for the lawful processing of patient data lies with the users (controllers). Depending on the privacy profile that is chosen by a user, the utilization of the service will involve the processing of anonymized patient data only or the processing of de-identified patient data that - despite of its de-identification - still qualifies as personal data. Siemens Healthcare GmbH informs (prospective) users of the service about the fact that it is their responsibility to collect patients' consent and release from medical confidentiality prior to uploading patient data to teamplay if they choose a privacy profile which does not provide for the anonymization of patient data. In such a case, the users of the service can revert to a high-quality template for the collection of patients' consent / release from medical confidentiality that is made available to them by Siemens Healthcare GmbH.

Technical Evaluator

Dipl. Math. Ralf von Rahden
datenschutz cert GmbH
Konsul-Smidt-Str. 88a
28217 Bremen
Germany

Legal Evaluator

Dr. Irene Karper LL.M.Eur.
datenschutz cert GmbH
Konsul-Smidt-Str. 88a
28217 Bremen
Germany

Initial Certification: 10/2016

Siemens Healthcare GmbH provides the cloud-based service teamplay to hospitals and other medical facilities making use of devices for medical imaging. teamplay allows its users to monitor (1) the utilisation of these devices in order to improve their image acquisition procedures and (2) the radiation dose consumption in order to identify doses which are as low as reasonably achievable to meet clinical needs. Customers are provided with meaningful information on how to make use of the service in compliance with EU data protection law. The legal requirements differ depending on which of the preconfigured settings of the service (privacy profiles) is chosen by the user: In one case, only anonymized patient data is processed, whereas patient data is de-identified, but still constitutes personal data in the two remaining cases. Users who adhere to the guidance provided by Siemens Healthcare can be sure that processing of patient data by means of teamplay is in line with EU data protection law.

https://teamplay.siemens.com  

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