ChairTab
Legal

Data Processing Agreement

This document is being prepared with legal advice and is not yet the published agreement.

What follows describes, in plain terms, how the software actually behaves today. It is accurate, and it is not a substitute for the document itself.

The roles

For patient data the clinic is the controller and ChairTab is the processor. We process patient data only to provide the service, on the clinic's instructions, and for no purpose of our own.

What we process

Patient identity and contact details, clinical notes, treatment and case records, photographs and radiographs. This includes health data, which is a special category under the GDPR and is treated as such throughout.

Access

Access within a clinic is decided by role, and enforced by the database: a laboratory technician is refused a medical history, a receptionist is refused clinical notes. Reads and writes of patient data are recorded.

Our own staff have no route to patient data through the console. The single channel through which text written inside a clinic reaches us is a support ticket, which the clinic composes deliberately. Opening a ticket thread on our side is recorded, and the content of a message can be removed on request while the ticket itself remains.

Location and sub-processors

Data is hosted within the European Union. The current sub-processors are our hosting and database providers, and a payment provider once billing is introduced. We will tell you before that list changes.

Return and deletion

On termination the clinic may export everything it holds, for ninety days. At the end of that window we erase what identifies people — patients, images, and the clinic's own staff records — and retain only the anonymous production record and our own commercial and correspondence records.

Breach

We will notify the clinic without undue delay after becoming aware of a personal data breach, so that the clinic can meet its own seventy-two hour obligation as controller.