The Unbreachable Resort: When Symfony Goes to Therapy with GDPR

Part I: GDPR in the Sanatorium-Type Hotel Business

Introduction: Why Does a Sanatorium Need GDPR?

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
• Information about sexual orientation (important for certain types of therapy)

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

Consent

The most obvious but most fragile ground:

• Must be explicit, informed, and revocable
• Special consent for processing medical data
• Problem: guest can withdraw consent at any time

Contract Performance

Main ground for hotel business:

• Guest registration
• Provision of booked services
• Billing and payment assurance

Legitimate Interests

Most complex for proper application:

• Safety of guests and staff
• Fraud prevention
• Service quality improvement
• Requires balancing with data subject rights

Vital Interests

Critical for medical aspects of sanatorium:

• Emergency medical care
• 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:

1. Audit of existing data processing processes
2. Creation of processing registry
3. Development of policies and procedures
4. Technical implementation of protection measures
5. Staff training
6. 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.