TRANSREG - National Registry of Discarded Blood Donors and Rare Red Cell Registry
Introductory information
One of our activities is the collection of blood from voluntary donors for the preparation of transfusion products. The provision of blood donations is a health service and therefore, particularly in relation to the scope of personal data processed, the same applies to donors as stated above in the information for patients. Nevertheless, in particular in the context of the need to maintain a high standard and safety of blood transfusions that are further used in humans, the processing of personal data is characterised by certain specificities, in particular the possible processing of personal data in the National Register of Discarded Blood Donors and the Rare Erythrocyte Register.
TRANSREG - National Register of Discarded Blood Donors and Rare Erythrocyte Registry
Transreg is a register that collects information on blood donors. This register is divided into two parts, which are kept for different purposes. The data contained in the Transreg register are shared between the various blood transfusion stations throughout the Czech Republic where necessary.
Excluded blood donors
European Union and Czech legislation sets very strict requirements that must be met by blood donors. Naturally, the most scrutinised is the donor's medical fitness to ensure that no disease is transmitted to the recipient of the donated blood. To this end, various examinations are carried out prior to donations. In some cases, the results of these tests may reveal that a potential donor is unfit to donate. Such a donor is then included in the Transreg register of discarded blood donors. Any other blood transfusion centre to which the person would come to donate blood can then check whether he or she is an ineligible donor. In this way, a high level of safety of blood transfusion can be achieved, even though some contraindications to blood donation may be difficult to detect at certain times. At the same time, this can save money on further tests.
The processing of personal data in the case of inclusion in the register of discarded blood donors occurs because it is necessary in the public health interest to ensure high standards of quality and safety of healthcare and medicines. Accordingly, the purpose of the Transreg registry is to increase the safety of transfusion products and thus reduce the risk of transmission of serious infections, as well as to facilitate the operations of transfusion service facilities and reduce the costs of providing health services by being able to obtain information on an excluded donor immediately, where necessary, without the need to carry out otherwise necessary tests.
The following data on excluded donors are processed in the Transreg registry: name, surname, birth number, blood group, health status (in particular the reason for exclusion from blood donation). The data are entered by the blood establishment that has identified the reason for exclusion of a particular donor. Both temporarily and permanently excluded donors are recorded in the register. Personal data relating to exclusion from donation will be deleted from the register whenever it appears that the reason for which the donor was included in the register no longer exists. Processing shall therefore take place for as long as is strictly necessary.
Rare blood donors
In the provision of health services, patients who are recipients of blood may be encountered who have special requirements in relation to blood transfusion. In particular, patients with rare blood types or other blood characteristics. For such patients, appropriate blood transfusion is not always available without further delay. At such times, the Rare Blood Donor Register can be used, which contains data on the blood group, Rh factor and phenotype of donors who have been assessed as rare by individual blood transfusion centres and who are eligible to donate blood to recipients with special requirements, under numerical codes. These donors may be approached and asked to come for blood donation if necessary.
The processing of data on rare donors is thus necessary in these cases for the provision of healthcare to recipients with special requirements. There is no doubt that timeliness of care can be crucial in many cases to save lives when blood transfusions are needed. The maintenance of a rare blood donor registry significantly reduces the time taken to find a suitable donor for recipients with special requirements, which can significantly increase the benefit of treatment.
In the Transreg registry, the following data are processed on rare donors: code number, blood group, Rh factor, phenotype. The data are entered by the blood establishment that has identified the reason for the inclusion of a particular donor.
What rights do you have in relation to your personal data?
As a data subject, data protection legislation gives you a number of rights. However, some of these are limited by the nature of the processing of personal data in the Transreg register. You have the following rights in relation to the personal data processed:
Right of access to personal data
You have, of course, the right to know what data is being processed about you, for what purpose, for how long, where we obtained the data, whether and to whom we are transferring it. You also have the right to be informed of your other rights in relation to this data. This document is mainly intended to inform you, but we are ready to provide you with confirmation or clarification on any point of this information.
Right to rectification of personal data
If you discover that the personal data we process about you is inaccurate or incomplete, you have the right to request that we complete or correct it without undue delay.
Right to restriction of processing of personal data
This right allows you to request, in certain cases, that certain of your personal data be marked and not further processed for a certain period of time. This is not the same as the right to erasure, as the restriction of processing is not permanent. You have the right to have us restrict the processing of your personal data if:
- you contest the accuracy of the data we process about you for the time necessary to verify its accuracy,
- we no longer need to process your personal data but you require it for the establishment, exercise or defence of legal claims,
If processing is restricted, the data may only be processed with your consent or for the establishment, exercise or defence of legal claims, for the protection of the rights of another person, whether natural or legal, or for reasons of important public interest.
Right to erasure
In certain cases, as a data subject, you may exercise the right to have your personal data erased, or the right to be forgotten. With regard to processing in the Transreg register, you will only be able to exercise this right where your personal data is no longer necessary for the purposes for which it was collected.
Right to lodge a complaint with a supervisory authority
The exercise of the rights set out so far is without prejudice to your right to lodge a complaint with the Data Protection Authority. You can find the current contact details directly on the website of the Data Protection Authority (www.uoou.cz). You can lodge a complaint at any time when you have doubts about whether your personal data is being processed as it should be, i.e. unlawfully or in breach of the law.
How can I exercise individual rights?
For all matters relating to the processing of your personal data, whether it is an enquiry, exercising a right, making a complaint or otherwise, you can contact our Data Protection Officer in the following ways:
- by post or in person at U Nemocnice 1, 128 00 Prague 2
- by e-mail at poverenec@uhkt.cz
We will process your request without undue delay, but within a maximum of one month. In exceptional cases, in particular due to the complexity of your request, we are entitled to extend this period by a further two months. We will, of course, inform you of any such extension and the reasons for it.