How we process data on your behalf.

1. Parties and roles

This Data Processing Agreement ("DPA") is between the practice that has accepted the RecallQ Terms of Service ("you", "the Practice") and Thomas William Groves, trading as RecallQ (ABN 84 202 664 713) ("RecallQ"). You decide which patient personal information is uploaded to the Service and the purposes for which it is used; RecallQ handles that information on your behalf and on your instructions to provide the Service.

2. Scope and instructions

RecallQ processes patient personal information only to provide the Service as described in the Terms of Service and Privacy Policy, and on your documented instructions. Your instructions are the settings you configure in the Service (for example, which patients are imported, which reminder rules are active, which channels are used, whether AI replies and staff notifications are switched on, and the FAQ text you supply). RecallQ does not sell, rent, or disclose patient information except to the sub-processors listed in clause 4 and as required by law.

3. What is processed

Patient names, mobile numbers, email addresses, dates of birth (where supplied), the practice's patient reference, last-visit and recall dates, booking details, consent and opt-out status, the content of messages sent and of patient replies (which may contain health information a patient chooses to write), and — on the Pro and Managed plans — the data sent to AI providers described in the Privacy Policy. The full list, with retention periods, is in the Privacy Policy sections 2 and 6.

4. Sub-processors and overseas handling

RecallQ uses the following sub-processors: Supabase (database, authentication and storage — Australia, Sydney), ClickSend (SMS — Australia), Resend (recall, account and staff-notification email — United States), Stripe (billing only, no patient data — United States, Stripe Australia entity), Vercel (website and portal hosting, cookieless analytics — United States, Sydney edge), Railway (application servers, patient data in transit only — Singapore), Anthropic (Pro and Managed plan AI — United States), OpenAI (Pro and Managed plan backup reply classification — United States), Sentry (error monitoring, patient information scrubbed before sending — European Union) and Google Workspace (our business and unsubscribe mailboxes — United States or other countries). The current list, the data each handles and any services not yet in use are on the legal hub. We will update that page when a sub-processor is added, removed or changes region, and will give you reasonable advance notice by email before a new sub-processor begins handling patient personal information, except where a change is needed urgently for security or continuity, in which case we will notify you as soon as practicable.

Patient personal information is stored only in Australia. Where a sub-processor outside Australia handles patient personal information (in transit in Singapore; email delivery and AI processing in the United States; mailboxes in the United States or other countries; scrubbed error reports in the European Union), RecallQ takes reasonable steps to ensure it is handled consistently with the Australian Privacy Principles, including sending only the minimum data needed and relying on each provider's published data-processing terms.

5. Security

RecallQ applies the safeguards described in section 9 of the Privacy Policy: tenant isolation enforced at the database level, encryption in transit (TLS) and at rest through our database host, authentication and least-privilege access controls, audit logging of key actions, removal of patient information from logs and error reports, signature verification of inbound provider messages, and periodic security review of the application.

6. Confidentiality and personnel

Only people who need access to patient personal information to provide, support or secure the Service are given access, and they are bound by confidentiality obligations.

7. Assistance with patient requests

If a patient asks you to access, correct or delete their information, RecallQ will help you respond, including by providing an export of, or deleting, that patient's records held in the Service, within the timeframes in section 8 of the Privacy Policy.

8. Data breach notification

If RecallQ becomes aware of unauthorised access to, disclosure of, or loss of your patient personal information, RecallQ will notify you without undue delay, and in any case within 72 hours of confirming that the incident affects your data, with the information reasonably needed for you to meet your own obligations under the Notifiable Data Breaches scheme. RecallQ will assess any suspected eligible data breach within 30 days and will notify the Office of the Australian Information Commissioner where required.

9. Staff notification emails

Where you switch on staff notifications, RecallQ emails patient names and short excerpts of patient replies to the contact email address you nominate in the Service. That address is chosen and controlled by you; you are responsible for ensuring it is correct and that only authorised staff can read it.

10. Return and deletion

You may request an export of your patient data for 30 days after your subscription ends. RecallQ deletes your patient personal information within 60 days after your subscription ends, except for audit records (which contain no patient names or contact details and are kept for 7 years) and billing records RecallQ must keep by law. Message content is in any case purged 90 days after each message is finalised.

11. Audit and information requests

On reasonable written request, no more than once a year, RecallQ will provide a written summary of its current security measures and sub-processors, and will answer reasonable questions you need answered to meet your own privacy obligations.

12. Term

This DPA applies for as long as RecallQ holds any of your patient personal information, and is governed by the same law as the Terms of Service.

13. Contact

Privacy, data-processing and security enquiries, and security incident reports: privacy@recallq.com.au.