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Backing up sensitive personal data for healthcare — KVKK § 6

Backup rules for dental clinics, dermatology, physiotherapy and pharmacies — dual compliance with the Ministry of Health and KVKK § 6 sensitive data.

Health data is the most strictly protected category under KVKK (Turkey's GDPR-equivalent). § 6/3:

"Sensitive personal data may be processed only if the adequate measures specified by the Board are taken."

KVKK Board decision no. 2018/10 (31 Jan 2018) lists those "adequate measures." Backup is one of them.

Which health data falls under § 6?

  • Patient appointment records + diagnoses (ICD codes)
  • Prescriptions + medication history
  • Lab results
  • Radiology images (DICOM)
  • Dental X-rays, dermatology photos
  • Physical therapy sessions
  • Genetic test results (treated as biometric)

⚠️ "Patient name + phone" alone is not sensitive (§ 3 personal data). But "John D. + tooth extraction" combined becomes § 6 health data.

The Board's adequate-measures list (2018/10)

Healthcare providers must implement the following 9 measures:

  1. Periodic employee training (at least yearly)
  2. Role-based access control
  3. Encrypted transmission and storage
  4. Backup ← the topic of this article
  5. Antivirus + firewall
  6. Logging (who accessed what, when)
  7. Physical security (locked room, cameras)
  8. Destruction at the end of retention
  9. Data-breach response plan

Dual compliance with the Ministry of Health

KVKK § 6 + Decree-Law no. 663 set the rules for private hospitals and clinics integrating with the Ministry's e-Nabız + MHRS systems:

  • Patient data may not be transferred abroad (§ 9 + Ministry of Health)
  • Systems generating e-Nabız reports must be certified
  • Backups are subject to the same cross-border restriction

PratikYedek runs 100% on Türkiye-based servers; there is no cross-border transfer concern.

A practical solution for dental clinics

A typical dental clinic (3 chairs, ~80 patients per week):

Assets to back up

Asset Size Frequency
PMS (Patient Management Software) DB 500 MB - 5 GB Hourly
Patient X-ray archive (DICOM) 50-500 GB Daily incremental
Treatment plan PDFs + consents 5 GB Daily
Billing DB 200 MB Hourly

Retention

KVKK § 7 and the Ministry of Health regulation overlap:

  • KVKK: data must be deleted once the purpose ends
  • Ministry of Health: patient files must be kept for 30 years (Regulation on Service-Providing Institutions)

Solution: kept encrypted with restricted access throughout retention. PratikYedek supports a 30-year retention lock.

Pharmacy context

Pharmacies must comply with MEDULA and KVKK simultaneously:

  • Prescription data is § 6 health data
  • MEDULA / SGK data may not leave Türkiye (by law)
  • Inventory + financial records: 5 years under VUK

The PratikYedek Phase 5 pharmacy preset:

  • Daily MEDULA log backup
  • E-signed prescription archive with separate encryption
  • Hourly stock-movement snapshots

Physical therapy centres

Patient exercise videos are often-skipped data:

  • § 6 biometric (movement is identifying)
  • Large video footprint (10-100 GB/month)
  • BYOS Google Workspace Drive is usually the most cost-effective fit for PT centres

Restore scenario — HIS outage

Say your dental clinic's HIS (Hospital Information System) breaks down after 15 patient appointments in the last 3 hours.

PratikYedek restore flow:

  1. Sign in to the dashboard with the master password
  2. Select the latest hourly snapshot + WAL replay → click "Restore"
  3. Restore to a fresh empty database (~8 minutes)
  4. Restart the HIS → all 15 appointments are back
  5. Net loss: 5 minutes

In the process:

  • No patient data was exposed to the server (E2E)
  • Audit log captured automatically
  • No KVKK § 12/5 breach (recovered from backup, no leak)

Breach scenario — the compliance frame

In case of a leak, you face § 12/5 + Ministry of Health dual notice:

  • KVKK Authority within 72 hours (online form)
  • Ministry of Health within 24 hours (specific alert)
  • Individual notice to patients (e-mail or KEP)
  • Criminal complaint (Cybercrime Bureau)

Certification and audit

PratikYedek targets for healthcare:

  • ✅ ISO 27001 (Phase 5 target)
  • ✅ ISO 27799 (health information security)
  • ✅ KVKK-approved standard contract (DPA)
  • ✅ Monthly restore drill evidence (audit-ready report)

PratikYedek healthcare package

  • ✅ E2E AES-256-GCM (you can even hold the KMS keys)
  • ✅ Türkiye-based servers (compliant with the Ministry + § 9)
  • ✅ DICOM image support (with compression)
  • ✅ 30-year retention lock (Ministry-compliant)
  • ✅ Automates 6 of the 9 adequate-measures

Join Early Access — A dedicated healthcare cohort.

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