Patient control
You decide. Always.
Nothing goes into your Passport without you, and nothing leaves it without you. You consent to the record being compiled. You name the doctor in Germany who receives it, and you can name a different one later. You can see everything that has been shared and with whom.
There is a second, separate question: whether an anonymised copy of your outcome may help future patients compare clinics. You can say no. If you do, nothing about your treatment or your aftercare changes.
Patient rights
Why this is even allowed
Moving medical data between countries sounds like the hard part. It isn’t — because you are the one moving it. Health data is a special category under Article 9 of the GDPR: it cannot be processed unless a specific exception applies, and your explicit consent is the first of them. Turkish law works the same way.
Article 20 already gives you the right to receive your own records in a structured, machine-readable format and pass them to whoever you choose — the Outcome Passport is that right made usable. From 2029 the European Health Data Space extends it specifically to health records. The direction of travel helps too.
Türkiye
Istanbul clinic
INTO EU
European Union
Hamburg doctor
Your record, Istanbul to Hamburg. An import into the Union. GDPR Chapter V does not restrict this direction.
Pre-op data before you travel, and outcome data returned for comparison. Restricted — explicit consent and standard contractual clauses.