The Unbreachable Resort: When Php Back End Goes to Therapy with GDPR, PCI DSS and HIPAA -> part one

Modern sanatoriums and resort complexes process massive amounts of personal data: from basic guest information to confidential medical data, financial transactions, and behavioral patterns.

GDPR (General Data Protection Regulation) is not just a regulator—it’s a privacy protection philosophy that should permeate the entire architecture of the hotel management system.

📊 Anatomy of Personal Data in a Sanatorium

Categories of data processed by a typical sanatorium:

🔵 Basic Personal Data:

Identification data (full name, passport data, addresses)
Contact information (phones, email, social networks)
Demographic data (age, gender, marital status)

🔴 Special Categories (particularly sensitive):

Medical data (diagnoses, contraindications, examination results)
Biometric data (fingerprints for access, photos for passes)
Physical and mental health information

🟡 Behavioral and Preferences:

Visit and booking history
Dietary preferences and allergies
Accommodation and service preferences
Financial information and payment history

🏗️ Privacy by Design: Architectural Principles

1. ⚡ Proactive vs Reactive

The system should prevent privacy violations rather than react to them. In the sanatorium context, this means:

✅ Automatic deletion of expired data
✅ Preventive anonymization of irrelevant records
✅ Real-time monitoring of access to sensitive data

2. 🔒 Privacy as Default Setting

Minimal set of mandatory fields during registration
Optional nature of additional data
Automatic application of the strictest privacy settings

3. 🎯 Full Functionality

Privacy protection should not reduce service quality:

✅ Service personalization through anonymized profiles
✅ Trend analytics without de-anonymization
✅ Efficient staff work while observing the principle of minimal necessity

⚖️ Legal Grounds for Processing: Balancing Interests

Legal Ground	Description	Use Case
🤝 Consent	The most obvious but most fragile ground	Must be explicit, informed, and revocable
📋 Contract Performance	Main ground for hotel business	Guest registration, services, billing
⚖️ Legitimate Interests	Most complex for proper application	Safety, fraud prevention, quality improvement
🚨 Vital Interests	Critical for medical aspects	Emergency medical care, life threats prevention

⚠️ Important Notes:

Consent: Special consent for processing medical data. Problem: guest can withdraw consent at any time
Contract Performance: Guest registration, provision of booked services, billing and payment assurance
Legitimate Interests: Requires balancing with data subject rights
Vital Interests: Prevention of life and health threats

📋 Data Processing Principles in Practical Application

1. 📢 Lawfulness, Fairness, Transparency

Clear privacy policy in understandable language
Processing purpose notifications at each stage
Visual data processing indicators in interfaces

2. 🎯 Purpose Limitation

Strict compliance with stated purposes
Prohibition on data processing for incompatible purposes
Documentation of all changes in processing purposes

3. ⚖️ Data Minimization

Collection of only necessary data
Regular audit of used fields
Deletion of unused data

4. ✅ Accuracy

Data verification procedures
Correction capabilities for data subjects
Automatic error detection and correction

5. ⏰ Storage Limitation

Storage policies for each data category
Automated deletion
Archiving with enhanced protection

6. 🔐 Integrity and Confidentiality

Encryption at all levels
Access control based on minimal necessity principle
Monitoring and auditing of all operations

👤 Data Subject Rights: Technical Implementations

📊 Right to Information and Access

✅ Automatic reports on collected data
✅ Self-service interfaces for data viewing
✅ Data export in structured formats

✏️ Right to Rectification

✅ Interfaces for self-editing
✅ Change verification procedures
✅ Third-party notifications about changes

🗑️ Right to Erasure (“right to be forgotten”)

✅ Automated deletion procedures
✅ Consideration of exceptions (legal storage requirements)
✅ Cascading deletion of related data

⏸️ Right to Restrict Processing

✅ Account “freezing” capability
✅ Data preservation without use
✅ Notifications about restriction removal

📤 Right to Data Portability

✅ Standardized export formats
✅ APIs for automatic data transfer
✅ Ensuring integrity during transfer

🚨 Breach Notification: Early Warning System

⏰ 72-Hour Window

Critical to have:

🔴 Automatic incident detection
🔴 Pre-prepared notification templates
🔴 Clear escalation and decision-making procedures

📈 Risk Assessment for Data Subjects

Automatic incident classification
Potential damage assessment models
Criteria for notifying data subjects

🌍 International Transfers: Global Sanatoriums

✅ Adequate Jurisdictions

Countries with European Commission adequacy decisions
Automatic transfer authorization

📄 Standard Contractual Clauses (SCCs)

Standard contracts for data transfers
Mandatory risk assessment in destination country
Additional protection measures when necessary

🏢 Binding Corporate Rules (BCR)

Intra-corporate rules for large sanatorium networks
Lengthy approval process
Maximum flexibility after approval

🏥 Specifics of Medical Data in Sanatoriums

🔒 Additional Guarantees

Professional medical confidentiality
Special consent requirements
Restrictions on automated processing

🔬 Research Purposes

Anonymization or pseudonymization
Special research participation consents
Ethics committees and their role

🛠️ Practical Implementation Recommendations

📋 Implementation Stages:

📊 Audit of existing data processing processes
📝 Creation of processing registry
📋 Development of policies and procedures
⚙️ Technical implementation of protection measures
👥 Staff training
🔄 Continuous monitoring and improvement

🎯 Critical Control Points:

⚠️ Integrations with external systems
⚠️ Backup procedures
⚠️ Mobile applications and their security
⚠️ Video surveillance systems and their database integration

📝 Conclusion of Part One

GDPR in the context of sanatorium business requires a comprehensive approach where legal requirements are transformed into technical solutions.

The particular complexity lies in processing medical data and the need to balance privacy requirements with the quality of medical services.