Privacy Statement
Important Notice
This platform collects and processes healthcare professional data for Continuing Professional Development (CPD) purposes. By using this platform, you consent to data collection and sharing as outlined below, including sharing with pharmaceutical sponsors.
The AiClinAudit collects multiple categories of data to provide educational services, facilitate sponsor partnerships, and improve healthcare practices:
1. Healthcare Professional Identity Data
- Personal Identifiers: Full name, email address, phone number (if provided)
- Professional Registration: AHPRA registration number and verification status
- Professional Details: Medical specialty, practice location, years of experience
- Account Information: User role (practitioner, admin, pharma brand manager), account creation date
- Authentication Data: Login credentials, session tokens, password reset requests
- Email Communication: Email addresses collected for sending completed audit reports and platform communications
2. Clinical Audit Data Structure
- Audit Metadata: Audit title, creation date, completion status, unique audit identifier
- Practitioner Information: Full name, AHPRA number (for verification and identification)
- Patient Cohort Data: De-identified patient profiles including age ranges, gender, clinical notes, and selection criteria
- Clinical Documentation: SOAP notes structure, transcribed content, voice-to-text metadata
- Literature Search Records: Search queries, PubMed results, AI-enhanced search metadata, processing times, and relevance scoring
- Professional Reflections: Learning outcomes, practice change intentions, clinical insights
- Pharmaceutical Sponsorship: Links to pharmaceutical company sponsors, access codes used, educational program participation
- Email Delivery Tracking: Email addresses used for report delivery, delivery status, message IDs, and timestamp records
- Audit Activity Logs: Complete audit trail of all actions, timestamps, user roles, and system interactions
3. Clinical Practice Data
- Audit Content: Clinical audit titles, objectives, methodologies, and outcomes
- Patient Cohort Information: De-identified patient demographics (age ranges, gender, conditions) and selection criteria
- Clinical Commentary: Professional observations, treatment approaches, clinical decision-making rationale
- Practice Patterns: Treatment protocols, medication choices, diagnostic approaches
- Professional Reflections: Learning outcomes, practice changes, educational insights
- Voice Recordings: Temporary audio data for transcription (deleted after processing)
4. Literature and Research Data
- Search Queries: PubMed searches, research topics, medical keywords
- Article Selections: Chosen publications, reading preferences, research interests
- Literature Analysis: Comments on research findings, clinical relevance assessments
- Evidence Evaluation: How research findings influence clinical practice
- AI Processing Metadata: LLM model usage, token consumption, processing times, parameter extraction, and relevance scoring data
5. Platform Usage Analytics
- Session Data: Login/logout times, session duration, feature usage frequency
- Navigation Patterns: Page visits, click-through rates, completion rates
- Interaction Data: Form submissions, search behavior, user preferences
- Performance Metrics: Audit completion rates, time spent on different sections
- Device Information: Browser type/version, operating system, screen resolution
6. Technical and Security Data
- Network Information: IP addresses, geolocation data (country/state level)
- Security Logs: Login attempts, security events, access patterns
- Error Reports: System errors, performance issues, crash reports
- Cookies and Tracking: Session cookies, preference cookies, analytics cookies
7. Pharmaceutical Sponsor Integration Data
- Sponsor Codes: Pharmaceutical access codes used to access sponsored audits
- Sponsor Linking: Which audits are linked to which pharmaceutical companies
- Brand Program Data: Participation in specific pharmaceutical educational programs
- Marketing Consent: Preferences for receiving sponsor communications
8. Administrative and Compliance Data
- Audit Trails: All user actions, data modifications, access logs
- Compliance Records: CPD requirements, completion certificates, educational credits
- Support Interactions: Help desk tickets, feedback submissions, technical support requests
- Legal Acknowledgments: Terms acceptance, privacy consent, data sharing agreements
- Email Communications: Audit report delivery records, email addresses used, delivery confirmations, and communication preferences
When you participate in a sponsor-branded audit (accessed via pharmaceutical company codes), the following data may be shared with the sponsoring pharmaceutical company:
Data Shared with Sponsors
Note: All data shared with pharmaceutical sponsors undergoes PII redaction, but sponsors receive detailed analytics about clinical practices and educational outcomes.
- Professional Profile: AHPRA number (as identifier), medical specialty, practice location (city/state level)
- Clinical Practice Patterns: De-identified treatment approaches, medication usage patterns, diagnostic criteria
- Educational Engagement: Audit completion rates, time spent on different sections, learning outcomes
- Literature Preferences: Research topics searched, articles reviewed, evidence evaluation
- Practice Insights: Clinical commentary (with PII redacted), professional reflections, practice change intentions
- Aggregated Patient Data: De-identified cohort demographics, condition prevalence, treatment outcomes
- Platform Usage: Feature utilization, engagement metrics, completion patterns
- Feedback and Assessments: Program evaluations, educational effectiveness ratings
Sponsor Use of Data
Pharmaceutical sponsors may use this data for:
- Medical Education: Developing targeted educational programs and resources
- Product Development: Understanding real-world clinical needs and treatment gaps
- Research and Development: Informing clinical research priorities and drug development
- Market Research: Understanding prescribing patterns and clinical decision-making
- Regulatory Submissions: Real-world evidence for regulatory filings and post-market studies
- Quality Improvement: Developing clinical guidelines and best practice recommendations
- Commercial Insights: Understanding market needs and competitive landscape
Data Retention by Sponsors
Pharmaceutical sponsors may retain shared data for up to 10 years for regulatory compliance, research purposes, and long-term educational program development. Sponsors are required to:
- Maintain data security standards equivalent to our own
- Use data only for the purposes outlined in their agreements with us
- Not attempt to re-identify de-identified data
- Comply with applicable privacy laws in their jurisdiction
- Provide data deletion upon reasonable request
PII Categories We Protect
We consider the following as PII requiring protection:
Patient PII (Strictly Protected)
- • Patient names, initials, or nicknames
- • Dates of birth, exact ages
- • Medical record numbers
- • Addresses, phone numbers
- • Email addresses
- • Social security numbers
- • Insurance information
- • Specific dates of treatment
- • Unique identifying characteristics
Practitioner PII (Selectively Protected)
- • Full contact details (shared with sponsors)
- • Practice names and addresses (city/state shared)
- • Personal phone numbers
- • Personal email addresses
- • Financial information
- • Family information
- • Personal identifiers beyond AHPRA
Automated PII Redaction Technology
We employ advanced AI-powered PII detection and redaction systems that:
- Real-time Scanning: All text input is scanned for PII patterns before storage
- Pattern Recognition: Identifies names, dates, addresses, phone numbers, email addresses
- Context Analysis: Uses natural language processing to identify potentially identifying information
- Voice Transcription Protection: PII redaction applied to all voice-to-text conversions
- Multi-language Support: PII detection across multiple languages and dialects
- Learning Algorithm: Continuously improves detection accuracy based on patterns
Manual Review and Quality Assurance
In addition to automated systems:
- Regular manual audits of redaction accuracy
- Staff training on PII identification and protection
- User education on avoiding PII entry
- Incident response procedures for PII exposure
- Regular system updates and improvements
Limitations and User Responsibility
Important: While our PII protection systems are comprehensive, they cannot guarantee 100% accuracy. Users remain responsible for avoiding entry of sensitive patient information and exercising professional judgment about data privacy.
Technical Security Measures
- Encryption: All data in transit and at rest is encrypted using industry-standard protocols (TLS 1.3, AES-256)
- Access Controls: Multi-factor authentication, role-based access controls, principle of least privilege
- Database Security: Encrypted databases with connection pooling and query monitoring
- Network Security: Firewalls, intrusion detection systems, DDoS protection
- Regular Security Audits: Penetration testing, vulnerability assessments, code reviews
- Monitoring: 24/7 security monitoring, automated threat detection, incident response
Administrative Security Measures
- Staff Training: Regular privacy and security training for all personnel
- Background Checks: Security clearances for staff with data access
- Data Access Policies: Strict policies governing who can access what data
- Audit Trails: Comprehensive logging of all data access and modifications
- Incident Response: Documented procedures for security breaches and data incidents
International Data Transfers
Data may be transferred to and processed in countries other than Australia for the following purposes:
- Cloud hosting and data storage (AWS, Google Cloud, Microsoft Azure)
- Pharmaceutical sponsor headquarters (US, EU, UK)
- Third-party service providers (analytics, support, security)
All international transfers comply with Australian privacy laws and include appropriate safeguards such as contractual protections and adequacy decisions.
Australian Privacy Laws
- Privacy Act 1988 (Cth): Full compliance with Australian Privacy Principles (APPs)
- Notifiable Data Breaches: Mandatory breach notification to OAIC and affected individuals
- Health Records Laws: Compliance with HRIPA 2002 and state-based health records legislation
- Telecommunications Privacy: Compliance with metadata and communications privacy laws
Healthcare Sector Compliance
- AHPRA Standards: Compliance with healthcare practitioner registration authority requirements
- Medical Board Guidelines: Adherence to professional conduct and privacy guidelines
- Clinical Trial Regulations: GCP compliance for research-related data
- Pharmaceutical Standards: Compliance with TGA and Medicines Australia industry codes
International Privacy Standards
Where applicable, we also comply with:
- GDPR: For EU-based pharmaceutical sponsors and users
- CCPA: For California-based pharmaceutical companies
- HIPAA: For US healthcare data handling requirements
- ISO 27001: Information security management standards
Retention Periods by Data Type
Clinical Audit Data
- • Active Audits: Retained indefinitely while audit is in progress
- • Completed Audits: 7 years from completion (regulatory requirement)
- • Abandoned Audits: 2 years from last activity
- • PDF Reports: Available for download indefinitely
User Account Data
- • Active Accounts: Retained while account is active
- • Inactive Accounts: 3 years from last login
- • Deleted Accounts: 30 days recovery period, then permanent deletion
- • Authentication Logs: 2 years for security purposes
Sponsor-Shared Data
- • Pharmaceutical Partners: Up to 10 years (their retention policies apply)
- • Aggregated Analytics: Retained indefinitely (anonymized)
- • Individual Insights: 5 years or until user requests deletion
Technical Data
- • Usage Analytics: 2 years for platform improvement
- • Error Logs: 1 year for debugging purposes
- • Security Logs: 7 years for compliance and investigation
- • Voice Recordings: Deleted immediately after transcription
Data Deletion Process
When data reaches its retention limit or upon user request:
- Soft Deletion: Data marked for deletion, access removed (30-day recovery period)
- Hard Deletion: Complete removal from all systems including backups
- Partner Notification: Pharmaceutical sponsors notified of deletion requests
- Verification: Deletion confirmation provided to users upon request
- Legal Holds: Data subject to legal proceedings retained until resolution
Data Subject Rights
Under Australian privacy law and our privacy commitments, you have the following rights:
1. Right to Access
- • Request a complete copy of all personal data we hold about you
- • Understand how your data is being processed and shared
- • Receive data in a commonly used, machine-readable format
- • Access data shared with pharmaceutical sponsors
2. Right to Rectification
- • Correct inaccurate personal information
- • Update outdated professional details
- • Modify audit content and clinical commentary
- • Update sponsor sharing preferences
3. Right to Deletion ("Right to be Forgotten")
- • Request deletion of your account and all associated data
- • Remove specific audits or clinical entries
- • Request deletion of data shared with sponsors (subject to their policies)
- • Permanent removal from all marketing communications
4. Right to Restrict Processing
- • Temporarily suspend data processing while disputes are resolved
- • Restrict sharing with specific pharmaceutical sponsors
- • Limit use of data for certain purposes (e.g., marketing)
- • Pause analytics processing while maintaining audit access
5. Right to Object
- • Object to data processing for marketing purposes
- • Opt out of data sharing with pharmaceutical sponsors
- • Object to automated decision-making and profiling
- • Withdraw consent for research participation
6. Right to Data Portability
- • Export your audit data to other platforms
- • Receive data in JSON, CSV, or PDF formats
- • Transfer data directly to other CPD platforms
- • Maintain data continuity when changing platforms
How to Exercise Your Rights
To exercise any of these rights:
- Email us: privacy@med-ed.ai with your request
- Include verification: Your AHPRA number and full name for identity verification
- Specify your request: Clearly state which right you wish to exercise
- Response timeline: We will respond within 30 days (or sooner if possible)
- Appeals process: If unsatisfied, you can appeal to the Office of the Australian Information Commissioner (OAIC)
Limitations on Rights
Some limitations may apply to these rights when:
- Data is required for legal compliance or regulatory obligations
- Information is needed for legal claims or defense
- Data has been anonymized and cannot be re-identified
- Processing is necessary for legitimate interests that override your rights
- Pharmaceutical sponsors have separate legal obligations to retain data
Technology Service Providers
- Cloud Hosting: Vercel (data hosting and processing)
- Database Services: PostgreSQL with Prisma Accelerate (data storage)
- Authentication: Auth.js v5 (secure login)
- Analytics: Vercel Analytics (usage tracking)
- Email Services: Resend (transactional emails)
- Payment Processing: Stripe (for paid features, if applicable)
Medical and Research Services
- PubMed/NCBI: PubMed/NCBI (literature search and retrieval services)
- Medical Databases: Clinical decision support tools and drug databases
- AI/ML Services: Cohere embedding models, Llama (text processing and PII redaction)
- Voice Processing: Speech-to-text services (temporary processing only)
Pharmaceutical Partner Services
- Data Analytics Platforms: Sponsor-specific analytics and reporting tools
- Marketing Platforms: Customer relationship management systems
- Research Platforms: Clinical research and real-world evidence systems
- Compliance Systems: Regulatory and compliance reporting platforms
Data Processing Agreements: All third-party services operate under strict data processing agreements that ensure the same level of privacy protection as outlined in this statement.
Privacy Contacts
General Privacy Inquiries
Email: privacy@med-ed.ai
Response Time: 2–3 business days
For: General questions, rights requests, complaints
Data Protection Officer
Email: dpo@med-ed.ai
Response Time: 1–2 business days
For: Serious privacy concerns, breach reports, compliance issues
Technical Security
Email: security@med-ed.ai
Response Time: Immediate (for critical issues)
For: Security vulnerabilities, suspicious activity
Sponsor Data Inquiries
Email: sponsors@med-ed.ai
Response Time: 3–5 business days
For: Questions about data shared with pharmaceutical partners
Regulatory Complaints
If you are not satisfied with our response to your privacy concerns, you may lodge a complaint with:
- Office of the Australian Information Commissioner (OAIC)
- Website: www.oaic.gov.au
- Phone: 1300 363 992
- Email: enquiries@oaic.gov.au
- Post: GPO Box 5218, Sydney NSW 2001
Privacy Statement Updates
We may update this Privacy Statement periodically to reflect changes in our practices, legal obligations, or business operations. Material changes will be communicated through:
- Email notification to all registered users
- Platform notification upon next login
- Website banner highlighting the changes
- 30-day advance notice for material changes
Version Information
Current Version: 2.0
Last Updated: 2025-07-06
Effective Date: 2025-07-06
Next Review: 2026-01-06
Major Changes in Version 2.0: Comprehensive pharmaceutical sponsor data sharing disclosures, enhanced PII protection details, expanded user rights, detailed retention policies.
By continuing to use the AiClinAudit after the effective date of any updates, you acknowledge that you have read and understand the revised Privacy Statement and agree to the updated practices.