Cookie handling

ELEMENTAL Day Surgical Center L.L.C · DHA licence 5323888

Which cookies the site sets, what they are for, and how you can change your choice at any time.

1. Our Commitment to Your Privacy

At ELEMENTAL Day Surgical Center, your privacy and the confidentiality of your personal and medical information are fundamental to our practice. We are fully committed to protecting your data in accordance with the highest international standards and all applicable laws of the United Arab Emirates. This Privacy Policy explains how we collect, use, share, store, and protect your personal information when you visit our centre, use our website, or communicate with us through any channel. By using our services, you agree to the practices described in this policy. If you do not agree with any part of this policy, please do not use our services or provide us with your personal information.

2. Legal Framework in the UAE

We strictly adhere to the following UAE healthcare and data protection laws as the legal basis for collecting and processing your personal and health data:

  • UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection (PDPL) – the main data protection law in the UAE. This law requires obtaining a specific, informed, and unambiguous indication of a person’s agreement to the processing of their personal data (Article 1).
  • UAE Federal Law No. 2 of 2019 (Health Data Law) – which governs the use and protection of health information specifically.
  • Dubai Health Authority (DHA) Regulations – including the DHA “Guidelines for Informed Patient Consent” and the NABIDH (National Unified Medical Record) framework for secure health data exchange.
  • Dubai Health Data Law No. 11 of 2018, which sets binding rules for the processing of health information in the Emirate of Dubai.

3. What Personal Data We Collect

To provide you with high-quality medical and surgical care, we may collect the following types of data:

  • Personal Identification: Full name, date of birth, gender, nationality, Emirates ID number, passport number, government‑issued ID.
    Contact Details: Residential address, phone number, email address, emergency contact information.
  • Medical Information (Sensitive Data): Medical history, current health conditions, diagnoses, prescriptions, laboratory results, imaging reports (X‑ray, CT, MRI, ultrasound), treatment records, before/after photos (with explicit written consent), anaesthesia protocols, surgery reports, discharge summaries, and any other clinical documentation directly related to your diagnosis, surgery, and postoperative care.
  • Financial & Insurance Information: Billing and payment information, health insurance details (policy number, provider name, coverage limits, co‑payments, deductibles), invoices, receipts, and any third‑party payer information required for claims processing or direct billing arrangements.
  • Website & Technical Data: IP address, browser type and version, device information, referring website, pages visited, appointment booking activity, form submissions, and cookies (essential and performance‑related).
  • Communication Records: History of your interactions with us via phone, email, WhatsApp, SMS, website live chat, social media DMs, and in‑person conversations, for the purposes of appointment scheduling, answering queries, and providing follow‑up instructions.

4. How We Use Your Personal Data

Your data is processed strictly for the following legitimate healthcare and operational purposes:

  • Medical Diagnosis and Surgical Treatment – to provide you with safe, appropriate, and effective surgical services, including preoperative assessment, intraoperative care, anaesthesia management, postoperative follow‑up, and rehabilitation.
    Patient Identification and Record Keeping – to maintain accurate and up‑to‑date electronic medical records as required by DHA and NABIDH standards. Your entire clinical file, including surgical notes, anaesthesia records, imaging studies, and laboratory results, is stored within the NABIDH (National Unified Medical Record) system of the Dubai Health Authority.
  • This ensures seamless, secure, and instantaneous access to your complete medical history by any authorised healthcare provider within the DHA network, improving clinical decision‑making and continuity of care.
  • Appointment Management – to schedule, confirm, reschedule, and remind you of appointments via phone, email, SMS, or WhatsApp.
  • Billing and Insurance Processing – to process payments, issue invoices, submit insurance claims, and liaise with insurance companies or third‑party administrators (TPAs) for payment settlement.
  • Compliance with UAE Healthcare Laws – to meet mandatory reporting obligations to the Dubai Health Authority (DHA), Ministry of Health and Prevention (MOHAP), and other regulatory bodies, including communicable disease notifications, quality audits, and public health reporting.
  • Internal Quality and Safety Improvement – to conduct audits, clinical research (only with anonymised data and after obtaining your explicit consent for any identifiable data use), and patient satisfaction surveys to continuously improve our services and patient outcomes.
  • Security and Fraud Prevention – to detect and prevent fraud, unauthorised access, and security breaches.
  • Marketing and Communications – to send you promotional offers, clinic news, and health education materials, but only with your explicit, freely given consent. You may opt out at any time.

5. Your Rights as a Data Subject

Under UAE data protection laws, you have the following rights regarding your personal data:

  • Right to Access – You have the right to request a copy of the personal data we hold about you. We will respond within 30 days.
  • Right to Correction – You have the right to request correction of inaccurate or incomplete personal data.
  • Right to Deletion (Right to be Forgotten) – You may request deletion of your personal data, subject to legal and medical record retention obligations under UAE law. Please note that clinical and surgical records must be retained for a minimum of 25 years from the date of your last visit, in compliance with DHA and MOHAP regulations. Non‑essential data (e.g., marketing communications) may be deleted upon request.
  • Right to Withdraw Consent – You have the right to withdraw your consent for non‑essential data processing (such as marketing or photography for promotional purposes) at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
  • Right to Restrict Processing – In certain circumstances, you may request restriction of processing of your data (e.g., while we verify its accuracy).
  • Right to Data Portability – You may request to receive your data in a structured, commonly used, machine‑readable format and to transmit it to another controller, where technically feasible.
  • Right to Object – You may object to processing for direct marketing purposes at any time.
  • Right to Lodge a Complaint – If you believe your data protection rights have been violated, you have the right to lodge a complaint with the Dubai Health Authority (DHA) and/or the UAE Data Protection Office.

To exercise any of these rights, please contact us using the details provided in Section 10 of this page.

6. Data Security and Retention

We implement state‑of‑the‑art technical and organisational security measures to protect your data from unauthorised access, disclosure, alteration, or destruction:

  • Encryption – All patient data is encrypted at rest and in transit using industry‑standard protocols (e.g., SSL/TLS).
  • Access Controls – Access to personal and medical data is strictly limited to authorised clinical and administrative personnel on a role‑based, need‑to‑know basis.
  • Regular Audits – We conduct regular internal and external audits to ensure compliance with DHA/NABIDH security requirements.
  • Data Localisation – In accordance with UAE Federal Law No. 2 of 2019, all health‑related data is stored on secure servers located within the United Arab Emirates. We do not transfer health data outside the UAE unless specifically authorised by the relevant health authority or required for your treatment (e.g., international second opinion with your explicit consent).

Retention Periods:

  • Medical records (clinical notes, surgical reports, anaesthesia records, imaging, lab results, consent forms) – retained for a minimum of 25 years from the date of your last visit, as mandated by DHA and MOHAP regulations.
  • Billing and insurance data – retained according to UAE VAT and tax record‑keeping rules (typically 5–10 years).
    Marketing consent data – retained until you withdraw your consent.
  • Website usage data (cookies) – retained for a maximum of 12 months or as per your browser settings.

Once the retention period expires, your data is securely anonymised or deleted.

7. How We Share Your Personal Data

We never sell, rent, or trade your personal data. We may share your data only in the following limited circumstances:

  • Healthcare Professionals Involved in Your Care – including surgeons, anaesthesiologists, nurses, radiologists, laboratory staff, and other clinical team members at ELEMENTAL Day Surgical Center.
    Dubai Health Authority (DHA) and Regulatory Bodies – as required by law, for mandatory reporting, audits, quality checks, and public health surveillance.
  • Health Insurance Providers – for billing, claims processing, pre‑authorisation, and payment settlement.
  • Third‑Party Service Providers – who assist in our operations (e.g., IT hosting within the UAE, laboratory services, radiology centres, payment processors, appointment reminder platforms), under strict confidentiality agreements that require them to protect your data to the same standards we do.
  • With Your Explicit Consent – for any other purpose not covered above (e.g., using before/after photos for marketing or educational purposes, participation in clinical research, or transferring records to another healthcare provider).

Your complete electronic medical record is shared within the DHA‑mandated NABIDH (National Unified Medical Record) network. This allows any DHA‑licensed healthcare provider who treats you to access your medical history, including surgical notes, anaesthesia records, imaging studies, and laboratory results, in real time.

This interoperability improves the speed, accuracy, and safety of your care, particularly in emergency situations. You have the right to opt‑out of the NABIDH network by completing a specific NABIDH Opt‑Out Consent Form [0†L22-L26], but please note that opting out may limit our ability to share your medical information with other providers in the event of an emergency.

8. Our Website and Cookies

Cookies – Our website uses essential, performance, and analytics cookies to enhance your browsing experience, remember your preferences (e.g., language), and help us understand how visitors interact with our site. You can disable non‑essential cookies through your browser settings at any time.

Third‑Party Links – Our website may contain links to external websites (e.g., social media platforms, insurance portals). We are not responsible for the privacy practices of those third‑party sites. We encourage you to read their privacy policies before providing any personal information.
Online Booking Forms – When you submit an appointment request or contact form through our website, we collect the information you provide (name, phone number, email, preferred date/time, reason for visit) solely for the purpose of responding to your request and scheduling your appointment.
No Medical Advice Online – Information provided on our website is for general informational purposes only and does not constitute medical advice. Always consult a qualified healthcare professional for personal medical guidance.

9. Disclaimer and Consent Acknowledgment

Consent is voluntary but required for treatment. By providing your personal data to us – whether in person, by phone, via our website, or through any other channel – you expressly consent to the collection, processing, storage, sharing, and transfer (where permitted) of your personal and health data as described in this Privacy Policy.

Withdrawal of consent. You may withdraw your consent for certain processing activities (e.g., marketing) at any time. However, withdrawal of consent cannot be applied retroactively and does not affect our legal obligation to retain medical records for the legally required period.

Consequences of refusing to provide data. If you choose not to provide required personal and medical information, we may be unable to provide you with healthcare services, process your insurance claim, or schedule your appointment.

10. Contact Us

If you have any questions, concerns, comments, or complaints regarding this Privacy Policy, your data protection rights, or how we handle your personal information, please contact us:

ELEMENTAL Day Surgical Center
113 Jumeirah St, Jumeirah 1, Dubai, UAE
+971 4 383 0500
appointment@elemental.ae