Privacy Policy

Last updated: 7/20/2025

1. Introduction

Surgi Homecare ("we," "our," or "us") operates the AI Triage clinical decision support platform. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our service.

We are committed to protecting the privacy and security of all personal and patient data processed through our platform, in compliance with GDPR, HIPAA, and other applicable healthcare data protection regulations.

2. Information We Collect

2.1 User Account Information

  • Name, email address, and professional credentials
  • Organization details and role within the organization
  • Professional license numbers (where applicable)
  • Login credentials and authentication data

2.2 Patient Data

Important: Patient data remains under the control of the healthcare organization. We act as a data processor, not a data controller.

  • Clinical assessment data entered into the platform
  • Patient demographics (as required for clinical algorithms)
  • Clinical test results and medical history
  • Triage decisions and clinical recommendations

2.3 Usage Data

  • Platform usage statistics and analytics
  • Feature usage patterns and performance metrics
  • Error logs and technical diagnostic information
  • Audit trails for compliance and security purposes

3. How We Use Information

3.1 Service Provision

  • Provide clinical decision support and triage recommendations
  • Process clinical data through our AI algorithms
  • Generate reports and analytics for healthcare organizations
  • Maintain user accounts and organization management

3.2 Platform Improvement

  • Improve algorithm accuracy and clinical recommendations
  • Enhance platform performance and user experience
  • Develop new features and clinical capabilities
  • Conduct research to advance clinical decision support (with appropriate anonymization)

3.3 Compliance and Security

  • Maintain audit trails for regulatory compliance
  • Monitor for security threats and unauthorized access
  • Comply with healthcare regulations and professional standards
  • Respond to legal requests and regulatory inquiries

4. Data Security

We implement comprehensive security measures to protect all data processed through our platform:

4.1 Technical Safeguards

  • End-to-end encryption for data in transit and at rest
  • Multi-factor authentication for user access
  • Regular security audits and penetration testing
  • Secure cloud infrastructure with redundancy and backup

4.2 Administrative Safeguards

  • Role-based access controls and principle of least privilege
  • Regular staff training on data protection and security
  • Incident response procedures and breach notification protocols
  • Vendor management and third-party security assessments

4.3 Physical Safeguards

  • Secure data centers with restricted physical access
  • Environmental controls and monitoring systems
  • Secure disposal of hardware and storage media
  • Business continuity and disaster recovery planning

5. Data Sharing and Disclosure

We do not sell, trade, or otherwise transfer patient data to third parties. Limited sharing may occur in the following circumstances:

  • Service Providers: Trusted third-party vendors who assist in platform operation (under strict data processing agreements)
  • Legal Requirements: When required by law, regulation, or court order
  • Emergency Situations: To protect the safety of patients or prevent serious harm
  • Business Transfers: In the event of a merger, acquisition, or sale (with appropriate safeguards)

6. Data Retention

We retain data only as long as necessary for the purposes outlined in this policy:

  • Patient Data: Retained according to healthcare organization policies and regulatory requirements
  • User Account Data: Retained while the account is active and for a reasonable period after closure
  • Audit Logs: Retained for compliance purposes as required by applicable regulations
  • Analytics Data: Aggregated and anonymized data may be retained for platform improvement

7. Your Rights

Under GDPR and other applicable laws, you have the following rights regarding your personal data:

  • Access: Request access to your personal data
  • Rectification: Request correction of inaccurate or incomplete data
  • Erasure: Request deletion of your personal data (subject to legal and regulatory requirements)
  • Portability: Request transfer of your data to another service provider
  • Restriction: Request limitation of data processing in certain circumstances
  • Objection: Object to certain types of data processing

8. International Data Transfers

If data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards are in place:

  • Standard Contractual Clauses approved by the European Commission
  • Adequacy decisions for countries with equivalent data protection standards
  • Additional technical and organizational measures to ensure data security

9. Children's Privacy

AI Triage is designed for use by healthcare professionals and is not intended for direct use by individuals under 18 years of age. We do not knowingly collect personal information from children under 18 outside of clinical care contexts.

10. Contact Information

For questions about this Privacy Policy or to exercise your rights, please contact:

Data Protection Officer
Surgi Homecare
Email: privacy@surgihomecare.com
Phone: +44 (0) 20 7946 0958
Address: [Company Address]

You also have the right to lodge a complaint with your local data protection authority if you believe your privacy rights have been violated.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify users of any material changes and obtain consent where required by law.