Sending a Patient Photo to the Manufacturer or Tech Support
Quick facts
- When
- Reporting an adverse event or asking for technical guidance on a product.
- Principle
- Restricted purpose, the minimum image, no data that identifies the patient.
- Channel
- Official channel of the manufacturer or health authority, not a personal chat.
- Record
- Note in the chart what was sent, when, to whom and why.
A nodule that will not resolve, an unexpected reaction, a batch that seems to behave differently. When something goes off script with a product, it is natural to contact the manufacturer or technical support. And the first request is usually "can you send a photo?". The photo helps clarify, but it carries the patient's identity. Sending it needs a method.
Why send the photo?
There are two legitimate purposes:
- Technical support: understanding whether the observed appearance is expected for the product and how to proceed.
- Adverse event reporting: recording a complication with a product with the health authority and the manufacturer, which contributes to the safety of other patients.
In both cases, the manufacturer or the authority does not need the whole face or the patient's name. They need the clinical appearance, the context and the product data.
What does the LGPD require?
The LGPD (Brazil's General Data Protection Law) asks for purpose, necessity and security. Applied to this case:
- Purpose: the sending is for support or reporting, not for other uses.
- Necessity: only what is needed for the purpose. If the relevant area is the lip, the whole face is excessive.
- Security: official channel, not a personal chat.
- Transparency: the patient should know the information may be shared.
For your specific case, consult a legal professional and your professional council's norms in Brazil.
How do you prepare the image?
On metadata, read metadata and location in patient photos. On eye bars, read does covering the eyes really protect?: the bar reduces identification but does not eliminate it.
What should you send along with the photo?
A photo without context has little value. A short, objective account helps whoever receives it:
| Information | Example |
|---|---|
| Product | Name, batch and expiration (from the label, not the patient) |
| Area | Upper lip, fold, temple |
| Time | Days since application |
| Symptom | Description of appearance, pain, warmth, color |
| Management | What has already been done |
| Course | Improved, worsened, stable |
| Age and sex | Age range, when relevant |
Avoid including name, address, phone or any data that identifies the patient. If the manufacturer asks for that data, assess the need and the legal basis before providing it.
What is the right channel?
Always prefer:
- Official reporting channel of the health authority, for adverse events.
- Official channel of the manufacturer (portal, corporate email, pharmacovigilance form).
- Identified technical representative, by corporate email.
Avoid: personal messaging app chats, groups, social media and unencrypted email, whenever there is an alternative.
What should the patient know?
Transparency is part of care. Explain that the information may be shared with the manufacturer and the health authority for safety, that their identity will be protected and that this does not change their treatment.
In serious cases, such as vascular occlusion, patient care is the priority and comes before reporting. Photo documentation is done without delaying clinical management. See complication photo: how to document.
What should be recorded in the chart?
- Date and time of sending.
- To whom it was sent and through which channel.
- Which images were sent and in what format.
- Purpose of the sending.
- Manufacturer's case protocol.
- Response and guidance received.
- Patient's awareness.
This record protects the patient, the professional and the traceability of the product.
Can the manufacturer use the photo for other things?
It is a question worth asking before sending. Ask the manufacturer to state, in writing, the purpose of processing, the retention term and whether it may be used in commercial materials. Using an image sent for support in marketing would be a misuse of purpose. If the answer is vague, prefer to send less information or use the health authority's official channel.
What about Harmy?
Harmy is not a reporting channel and should not be used to send images to a manufacturer. The image generated in the app is an illustrative simulation and does not document a complication. Adverse event reporting should be done with real photos, in the chart and through the official channels.
Summary for your routine
Have a purpose, send the minimum, remove identifying data, use an official channel, inform the patient and record everything in the chart. For the consent overview, see consent and LGPD in patient photos and sharing a photo with another professional.
Frequently asked questions
Can I send the patient's photo to the product manufacturer?
You can, when there is a legitimate purpose, such as reporting an adverse event or asking for technical guidance, sending the minimum necessary, without data that identifies the patient and through an official channel.
Do I need the patient's authorization?
Ideally, inform the patient and, if possible, have it provided for in the consent form. For safety notifications, the rules may vary. Consult a legal professional and your professional council's norms.
What should I do to anonymize the photo?
Crop the relevant area, remove the name and documents, strip the metadata and, if possible, avoid the whole face. Remember that truly anonymizing a face is hard, so send the minimum.
Is there an official channel to report an adverse event?
Yes, the health authority maintains channels for reporting adverse events with health products. In Brazil, check the ANVISA website for the current procedure.
Harmy images are illustrative simulations generated by AI from the patient's photo to support the conversation between practitioner and patient. They are not a promise of results. Indication, technique, product and volume are solely the decision of the licensed practitioner. This content is for information only and does not replace a clinical assessment.