UK GDPR and your data processing agreement

  • Owner
Updated 3 min read
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Who is the data controller?

Your clinic. For patient data, your clinic is the controller and Clinicify is the processor. You decide what’s recorded, why and for how long, and Clinicify acts on your instructions. For your staff accounts and billing, Clinicify is the controller, and our privacy policy covers that.

Do we need to sign a data processing agreement?

No. Our data processing agreement (DPA) forms part of the terms of service, so accepting those covers it. If your own governance process needs a countersigned copy, the DPA page explains how to ask for one.

What does the DPA cover?

It’s the agreement UK GDPR Article 28 requires between a controller and a processor. It sets out what data we process and why, the security measures we use, how we help you answer patient requests, how we notify you of a breach, international transfers, your audit rights, and how data is returned and deleted when you leave. Read it in full at /dpa/.

Who else handles our data?

Clinicify uses sub-processors for parts of the service, such as sending emails and text messages. The current list, with what each one does and where it is, is in our privacy policy. Some, such as calendar, video and accounting integrations, only receive anything if you connect them. The DPA explains how we tell you about changes and your right to object.

Is patient data used to train AI?

No. Patient data isn’t sold and isn’t used to train AI models. The AI provider behind Clinicify’s AI doesn’t keep patient data. See How patient data is protected.

What do we need to do as the controller?

Have a lawful basis for the data you record, tell patients how you use it in your own privacy notice, manage your team’s access, and keep clinical records for as long as your regulator requires, including after you stop using Clinicify. Set your retention periods in Data & retention. See How long records are kept.

How do we handle a patient’s request for their data or for erasure?

Most of it happens in the app: you can export, correct and archive a patient record yourself, and an owner processes erasure requests. Owners are emailed when a patient asks for erasure from the patient portal. See Handling patient data and erasure requests.

What happens to our data if we leave?

You can export your clinic’s data at any time, and for 90 days after your subscription or trial ends. Treatment photos aren’t included in the export. After those 90 days, your clinic’s data is permanently deleted. See Export your clinic’s data.

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