Complaints channel

1. What this channel is

The complaints channel is Salud en Ruta's way of receiving two types of communication: complaints about the care or service you received, and reports of irregularities, conduct contrary to professional ethics or regulatory breaches related to our activity.

Complaints about the service are handled as consumer complaints. Ethics and compliance reports are managed as an Internal Reporting System, with the safeguards of Spanish Law 2/2023 on the protection of persons who report regulatory breaches and on the fight against corruption.

In both cases, the communication is reviewed by the team responsible for the channel, not by the professional or department it concerns.

2. Who can use it

Anyone who has or has had a relationship with Salud en Ruta can use this channel, including:

• Patients and relatives: people seen during a visit and those who requested it or were present.
• Clients: private individuals who have used the service and the insurers and intermediaries that send us requests.
• Professionals and collaborators: doctors, nurses and coordination and administrative staff, current or former, and people taking part in a recruitment process.
• Suppliers and subcontractors: companies and self-employed professionals who work with us.

3. What can be reported

Through this channel you can report, for example:

Complaints about the service

• Care received: the quality of the medical or nursing care.
• Arrival time: significant delays compared with the window you were given.
• Professional's manner: the way any member of our team treated you.
• Billing: amounts, charges or invoices that do not seem correct to you.
• Data protection: the use of your personal or health data.
• Website or portal: problems with the website or the provider portal.
• Other: any other aspect of the service you are not satisfied with.

Ethics and compliance reports

• Legal breaches: infringements of healthcare, labour, tax or data protection rules, or of any other regulation.
• Breaches of professional ethics: professional conduct contrary to ethics or to codes of professional conduct.
• Harassment or discrimination: workplace or sexual harassment or discriminatory conduct towards anyone.
• Corruption or fraud: bribery, undisclosed conflicts of interest or misuse of company resources.

4. How to report it

You can submit your communication in writing using the guided form, explaining in as much detail as possible what happened, when, who was involved and whether you have any evidence. You can identify yourself with your name and email, so that we can confirm receipt and tell you the outcome, or indicate that you prefer not to identify yourself.

Verbally too: ethics and compliance reports can be made verbally: write to the channel manager's email to ask us to call you or to request a face-to-face meeting, which will take place within the following seven days. A written record of the conversation is kept, or a recording if you authorise it, and you are offered the chance to check, correct and sign it.

5. Safeguards and time limits

This channel is managed with the following safeguards:

• Confidentiality: the identity of the person reporting is not disclosed to third parties without their express consent, except where legally required in a judicial or administrative investigation, in which case they are notified beforehand whenever possible.
• Acknowledgement of receipt: if you identify yourself, we confirm receipt within seven calendar days at most, with a tracking code.
• Reply to service complaints: we reply as soon as possible and, in any case, within the maximum period of one month set by consumer protection law.
• Reply to ethics reports: the investigation is concluded within three months at most from the acknowledgement of receipt, extendable by a further three months in particularly complex cases, in which case you are told about the extension and its reasons.
• No retaliation: no retaliation of any kind is allowed against anyone who reports in good faith or against those close to them. Anyone who retaliates will be held accountable.
• Right to be heard: the person the facts relate to is informed and can give their version, with respect for the presumption of innocence and without being told who made the report.
• Register: ethics and compliance reports are recorded in a confidential register, which is only made available to the judicial authority upon a reasoned request.

6. Other channels

Using this channel does not prevent you from using other channels, and you do not have to exhaust it first. You can also contact:

• Consumer affairs: if you are a consumer, you can ask us for the official complaint form or go to your municipal consumer information office or the consumer services of the Community of Madrid, which also offer consumer arbitration.
• Health authorities: the Regional Ministry of Health of the Community of Madrid, regarding the healthcare provided.
• Spanish Data Protection Agency: if your complaint concerns the processing of your personal data.
• Independent Authority for Whistleblower Protection (A.A.I.): the external channel provided for in Law 2/2023, which you can use with or without a prior internal report, including anonymously.
• Other authorities: any regional whistleblower protection authorities within their remit and, where the breach affects European Union law, the EU institutions, bodies and agencies.

Using an external channel does not cost you any of the protections of Law 2/2023. If the facts could constitute a criminal offence, the information is forwarded to the Public Prosecutor's Office.

7. Data protection

The processing of data in this channel is governed by the GDPR, the LOPDGDD and, for ethics and compliance reports, Law 2/2023, with the following particularities:

• Legal basis: compliance with a legal obligation (art. 6.1.c GDPR): the obligation to handle consumer complaints, or to have an Internal Reporting System. That is why you are not asked for consent, but to confirm that you have read this information.
• Health data: if your complaint concerns a visit, it may be necessary to consult the clinical record to investigate it, under art. 9.2.h GDPR and always subject to professional secrecy. Do not include more health data in your communication than is strictly necessary.
• Minimal data: only the data needed to handle the communication is processed. Any data that is not needed, or that is provided by mistake, is deleted.
• Retention period: service complaints are kept for as long as needed to resolve them and then for the limitation periods of any potential liability. Ethics reports are deleted three months after receipt if no investigation has been opened, leaving only an anonymised entry in the register.
• Limited access: only the people responsible for managing the channel and, where appropriate, those who must investigate the case or take action have access to the data.
• Your rights: you can exercise the rights explained in the privacy policy, with the limitation that they do not give access to the identity of whoever submitted an ethics report.

8. Contact

For any question about how the channel works, or to request a face-to-face meeting: