GDPR Compliance Declaration
Download a copy of the GDPR Compliance Declaration
1. What is Face2Gene?
Face2Gene is a suite of phenotyping applications that facilitates comprehensive and precise genetic evaluations. FDNA, Inc. (“FDNA”) uses facial analysis, deep learning, and artificial intelligence to transform big data into actionable genomic insights to improve and accelerate diagnostics and therapeutics.
With the rapid advance of healthcare technologies – such as mobile medical apps and cloud computing – and their increasing integration with social media, personal data1 protection has become of paramount importance.
The European Union has adopted the EU General Data Protection Regulation 2016/679, known as the General Data Protection Regulation (“GDPR“). As a company with EU users, FDNA has taken certain actions and has adopted policies and procedures in order to implement the GDPR to enhance the data protection of the personal data of its EU users.
3. Steps implementing GDPR
FDNA has implemented the appropriate safeguards to meet GDPR requirements as part of a corporate commitment to protecting personal data through a strong security and privacy compliance management; for instance:
- Creating a data mapping inventory mapping all our data flows, differentiating between personal data and non-personal data. We are constantly updating and maintaining this data mapping as a record of our processing activities.
- Mapping and determining our lawful basis for processing of personal data.
- Putting in place or updating existing data protection policies, such as an updated Information Security Policy, Data Subject Access Request Policy, Incident Management Procedure, and Retention Policy.
- Implementing an authentication system that ensures that a person is in fact who he or she claims to be before being allowed access to the application.
Personal data under GDPR means any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Updating the customer contact processes and implementing communication preference-setting systems.
- Adjusting security measures to be adequate and appropriate under the GDPR principles to the types of personal data we process. For more information about our information security measures please visit: www.face2gene.com/security-privacy.
- Putting in place appropriate internal procedures for breach notification; these are detailed in the company SOP (Standard operating procedure) for Incident Response.
- Updating the backup processes to be aligned to our Retention Policy and GDPR data retention principles.
- Updating our list of sub-processors and amended our terms of agreement with them to comply with GDPR.
- Appointing a data protection officer (DPO), which is in charge, globally, to protect the personal data of our users and to align our relevant policies with the GDPR. Our DPO’s contact details are as follows: email@example.com.
- Designating a representative, who should act on behalf of FDNA and may be addressed by any EU supervisory authority.
- Conducting regular and periodical risk analysis for its products analyzing software and data security as well as the data protection impact assessment where required under GDPR.
- Implementing appropriate internal procedures to ensure that the secure processing of personal data is further safeguarded by the general duty on employees, to ensure that data remain confidential.
- Maintaining a record of processing activities under FDNA’s responsibility that contains all of the information required by Art. 30 GDPR.
- Using “Standard Contract Clauses” (SCC) approved by the EU Commission to ensure compliance with applicable EU data protection and privacy regulations for its EU users.
4. Data minimization
Pursuant to the data minimization principle provided for in Art.5.1.(c) GDPR, FDNA does not store health information that allows the identification of a patient, such as name, address, dates and identifying numbers, other than facial photographic images. These images may be uploaded if user has obtained an appropriate informed consent. Facial photographic images uploaded by users of Face2Gene are stored in an encrypted file volume on our servers in Ireland and are not accessible by other users of Face2Gene by default, unless explicitly and actively designated otherwise by the user. An automatic learning algorithm is applied anonymously on all facial photographic images stored in its Face2Gene file volume in order to train and improve the FDNA Technology.
If you have any questions about the way we handle your personal data, whether under GDPR or other laws applicable to you, please contact our DPO at firstname.lastname@example.org.
Last Updated: January 1, 2023
Face2Gene User Community Includes Users From:
Using Face2Gene to reference all my department’s cases, share information with my colleagues and quickly look up relevant information in the London Medical Databases Online saves me hours of work every week and allows me to focus on my patients.
Dr. Ibrahim Akalin
Assoc. Prof. Ibrahim Akalin, MD, Medical Geneticist from the Istanbul Medeniyet University, Istanbul, Turkey
FDNA’s game-changing technology introduces an objective computer-aided dimension to the “art of dysmorphology”, transforming the analysis into an evidence-based science.
Dr. Michael R. Hayden
Chairman of FDNA’s Scientific Advisory Board & Steering Committee and Editor in Chief of Clinical Genetics
FDNA is developing technology that has the potential to help so many physicians and families by bringing them closer to a diagnosis- there are literally millions of individuals with unusual features around the world that lack a diagnosis and therefore lack information on natural history, recurrence risk and prevention of known complications.
Dr. Judith G. Hall
Professor Emerita of Pediatrics & Medical Genetics UBC & Children's and Women's Health Centre of BC
FDNA has been “right on the money”, providing me with relevant, accurate and insightful information for differential diagnoses.
Dr. Cynthia J.R. Curry
Professor of Pediatrics UCSF, Adjunct Professor of Pediatrics Stanford
I am excited to be a part of the FDNA community, promoting broad information sharing with my peers to amplify the scientific and clinical value of our community’s accumulated knowledge for the purpose of efficiently diagnosing individuals with rare genetic disorders.
Dr. Karen W. Gripp
Chief, Division of Medical Genetics A.I. duPont Hospital for Children
FDNA's idea of incorporating several dysmorphology resources (OMIM, GeneReviews), supported by their visual analytic technology, will be able to improve researching of genetic syndromes - all within a single mobile app.
Dr. Chad Haldeman-Englert
Assistant Professor Pediatrics at Mission Fullerton Genetics
Given the advancement of visual analytical technology, it’s about time Dysmorphology is supported with computational capabilities and moving this to mobile support, is simply the next logical step.
Dr. Chanika Phornphutkul
Associate Professor of Pediatrics Director, Division of Human Genetics Department of Pediatrics Warren Alpert Medical School of Brown University
Having an archive of cases easily accessible from my mobile device anytime and anywhere is a long-time unmet need.
Dr. Lynne Bird
Rady Children's Specialists of San Diego
FDNA's solution is a huge leap forward for dysmorphology. It saves me significant time when I’m evaluating patients in my clinic and provides me with insightful tools that help me generate a differential diagnosis.
Dr. David A. Chitayat
Head of the Prenatal Diagnosis and Medical Genetics Program at Mount Sinai Hospital, Toronto
Shortly after learning about Face2Gene, I’ve started to incorporate this amazing tool into my workflow. Soon enough, Face2Gene’s analysis flushed out references that I would not have considered for several of my patients, which turned out to be their correct diagnosis
Dr. Zvi U. Borochowitz
Chairman (Retired) of The Simon Winter Institute for Human Genetics at Bnai-Zion Medical Center, Technion-Rappaport Faculty of Medicine
The Unknown Forum from Face2Gene is a great community platform for exchanging opinions regarding undiagnosed cases. It is straightforward to use and safe for exchange of medical data, thanks to the efforts of its developers and to the involvement of geneticists worldwide.
Dr. Oana Moldovan
Clinical Geneticist at the Hospital Santa Maria, CHLN, Lisbon, Portugal