4.1 Technology Products

• Hardware deployment and maintenance

• Software licensing and support

• AI model development and deployment

• System integration services

4.2 Digital Pathology Services

• Telepathology consultations and second opinions

• Digital slide scanning and analysis

• AI-assisted diagnostic support

• Pathology reporting and case management

4.3 Digital Radiology Services

• Medical imaging analysis and interpretation

• Radiological consultations

• AI-powered image enhancement and analysis

• Radiology reporting services

4.4 Biopharma Services

• Sample processing and analysis

• Clinical trial support

• Research data management

• Biomarker analysis

4.5 Website and Digital Platforms

• Website interactions (www.digidxdoc.com)

• Customer portals and dashboards

• Mobile applications

• Marketing communications

5.1 General Personal Data

• Identity Information: Name, contact details, professional credentials

• Technical Data: IP addresses, device information, system logs

• Communication Data: Email correspondence, chat logs, support tickets

• Financial Data: Billing information, payment details (processed by certified payment processors)

5.2 Health and Medical Data

• Diagnostic Images: Pathology slides, radiology images, microscopy data

• Medical Records: Patient history, symptoms, clinical notes

• Diagnostic Reports: Pathology reports, radiology interpretations, second opinions

• Genetic Information: Genomic data, biomarker information, hereditary data

• Biometric Data: Image analysis results, morphometric measurements

5.3 Research and Development Data

• Clinical Trial Data: Study participant information, trial results

• AI Training Data: Anonymized datasets for machine learning model development

• Performance Metrics: Diagnostic accuracy data, system performance indicators

• Research Analytics: Statistical analyses, outcome measurements

5.4 Operational Data

• User Activity: System usage patterns, feature utilization

• Quality Metrics: Turnaround times, accuracy measurements

• Audit Logs: Access records, system modifications, security events

6.1 Direct Collection

• Patient Portals: Information provided directly by patients

• Healthcare Providers: Data submitted by referring physicians and institutions

• User Registration: Account creation and profile setup

• Service Requests: Consultation requests and case submissions

6.2 Indirect Collection

• Partner Institutions: Healthcare organizations, laboratories, research centers

• Medical Devices: Automated data collection from diagnostic equipment

• Third-Party Systems: Integration with hospital information systems, PACS

• Public Sources: Medical literature, published research (for AI training)

6.3 Automated Collection

• System Logs: Technical performance and security monitoring

• Device Telemetry: Equipment performance and maintenance data

• Usage Analytics: Platform interaction and feature utilization

• Quality Monitoring: Automated quality control measurements

7.1 Healthcare Service Delivery

Purpose: Providing diagnostic services, consultations, and medical opinions

Legal Basis:

• Legitimate interest in healthcare delivery

• Consent for specific services

• Vital interests for emergency diagnostics

• Legal obligation under healthcare regulations

7.2 Research and Development

Purpose: AI model development, clinical research, product improvement

Legal Basis:

• Explicit consent for research participation

• Legitimate interest in medical advancement

• Compliance with research ethics approvals

7.3 Regulatory Compliance

Purpose: Meeting healthcare regulations, quality assurance, audit requirements

Legal Basis:

• Legal obligation under healthcare laws

• Compliance with medical device regulations

• Professional standards adherence

7.4 Business Operations

Purpose: Customer support, billing, contract management

Legal Basis:

• Contract performance

• Legitimate interest in business operations

• Legal obligation for financial record-keeping

8.1 Layered Consent Structure

We implement granular consent mechanisms allowing individuals to choose:

• Essential Services: Core diagnostic and consultation services

• Enhanced Analytics: AI-powered diagnostic assistance

• Research Participation: Contribution to medical research and AI development

• Marketing Communications: Educational content and service updates

• Data Sharing: Collaboration with research institutions and partners

8.2 Consent Withdrawal

You may withdraw consent at any time through:

• Patient Portal: Online consent management dashboard

• Written Request: Email or postal communication

• Healthcare Provider: Through your referring physician

• Direct Contact: Our Data Protection Officer

Important: Withdrawal of consent may impact our ability to provide certain services, particularly ongoing medical consultations.

8.3 Emergency Situations

In urgent medical situations, we may process data based on vital interests without explicit consent, in accordance with healthcare emergency protocols.

9.1 Internal Recipients

• Medical Professionals: Pathologists, radiologists, clinical specialists

• Technical Teams: IT support, system administrators (with appropriate access controls)

• Quality Assurance: Teams responsible for service quality and compliance

• Research Teams: For approved research projects (with appropriate safeguards)

9.2 External Healthcare Partners

• Referring Physicians: Diagnostic reports and clinical recommendations

• Healthcare Institutions: Partner hospitals, clinics, and laboratories

• Specialist Consultants: External medical experts for complex cases

• Laboratory Networks: For additional testing or confirmation

9.3 Service Providers

• Cloud Infrastructure: Certified healthcare cloud providers (AWS HIPAA, Azure Health)

• Technology Partners: Medical device manufacturers, software developers

• Support Services: Technical support, maintenance providers

• Professional Services: Legal, audit, compliance consultants

9.4 Research Collaborators

• Academic Institutions: Universities and research centers

• Biopharma Companies: For clinical trial support and drug development

• Medical Societies: For clinical guidelines and best practice development

• Regulatory Bodies: For post-market surveillance and safety monitoring

9.5 Legal and Regulatory

• Regulatory Authorities: FDA, EMA, local health authorities

• Legal Authorities: Courts, law enforcement (with appropriate legal process)

• Accreditation Bodies: For quality certification and compliance verification

Data Sharing Safeguards:

• All recipients are bound by confidentiality agreements

• Data sharing agreements include appropriate technical and organizational measures

• Access is limited to the minimum necessary for the specified purpose

• Regular audits ensure compliance with data sharing agreements

10.1 Data Residency

• EU/EEA Data: Primarily stored in EU-based data centres

• US Data: Stored in HIPAA-compliant US facilities

• Multi-jurisdictional: Replicated across regions for business continuity

10.2 Transfer Safeguards

When transferring data internationally, we implement:

• Adequacy Decisions: Utilizing European Commission adequacy findings

• Standard Contractual Clauses (SCCs): For transfers to non-adequate countries

• Binding Corporate Rules: For intra-group transfers

• Certification Schemes: Healthcare-specific data protection certifications

10.3 Cross-Border Consultations

For international medical consultations:

• Explicit consent for cross-border data sharing

• Equivalent privacy protection guarantees

• Secure transmission protocols

• Clear data retention and deletion timelines

11.1 AI-Assisted Diagnostics

Our AI systems provide:

• Diagnostic Support: Assistance to medical professionals (not replacement)

• Image Analysis: Pattern recognition and abnormality detection

• Risk Assessment: Statistical analysis and outcome prediction

• Quality Enhancement: Image optimization and artifact reduction

11.2 Human Oversight

• All AI-generated outputs are reviewed by qualified medical professionals

• Final diagnostic decisions always require human validation

• Patients have the right to request human-only analysis

• Clear distinction between AI assistance and human interpretation

11.3 AI Model Training

• Data Minimization: Only necessary data used for training

• Anonymization: Personal identifiers removed from training datasets

• Bias Prevention: Regular testing for algorithmic bias and fairness

• Performance Monitoring: Continuous evaluation of model accuracy and reliability

11.4 Transparency Rights

You have the right to:

• Know when AI is used in your diagnostic process

•Understand the logic and potential consequences of AI assistance

• Request human review of AI-generated recommendations

• Access information about AI model performance and limitations

12.1 Technical Safeguards

• Encryption: AES-256 encryption for data at rest and in transit

• Access Controls: Multi-factor authentication, role-based access

• Network Security: Firewalls, intrusion detection, VPN access

• Backup Systems: Encrypted, geographically distributed backups

12.2 Organizational Measures

• Staff Training: Regular privacy and security awareness programs

• Access Management: Principle of least privilege, regular access reviews

• Incident Response: 24/7 security monitoring and response procedures

• Vendor Management: Due diligence and ongoing monitoring of service providers

12.3 Healthcare-Specific Security

• HIPAA Compliance: Administrative, physical, and technical safeguards

• Medical Device Security: FDA cybersecurity guidelines implementation

• Audit Logging: Comprehensive tracking of all data access and modifications

• Business Associate Agreements: Contractual protections with all service providers

12.4 Physical Security

• Data Centers: Biometric access controls, environmental monitoring

• Equipment Security: Device encryption, secure disposal procedures

• Facility Protection: Access controls at all DigiDxDoc locations

• Transport Security: Secure courier services for physical media

13.1 General Retention Principles

• Minimum Necessary: Data retained only as long as required for specified purposes

• Legal Compliance: Adherence to healthcare record retention requirements

• Active Deletion: Automated deletion processes after retention periods

• Anonymization: Conversion to anonymous data for long-term research use

13.2 Specific Retention Periods

Diagnostic Records:

• Patient diagnostic reports: 10 years (or as required by local law)

• Medical images and slides: 7 years minimum

• Emergency consultation records: As required by applicable healthcare laws

Research Data:

• Clinical trial data: As required by regulatory authorities (typically 15–25 years)

• AI training datasets: Until model retirement or regulatory requirement

• Published research data: Indefinitely in anonymized form

Operational Data:

• User account information: 3 years after account closure

• System logs: 1 year for security logs, 3 months for operational logs

• Communication records: 3 years for service-related communications

Financial Records:

• Billing and payment data: 7 years as required by financial regulations

• Contract and agreement records: Duration of contract plus 7 years

13.3 Deletion Procedures

• Secure Deletion: NIST-compliant data destruction methods

• Backup Purging: Removal from all backup systems

• Third-Party Notification: Instruction to service providers for data deletion

• Verification: Confirmation of successful data deletion

14.1 Access Rights

• Data Access: Copy of all personal data we hold about you

• Processing Information: Details about how and why we process your data

• Source Information: Where we obtained your data

• Sharing Details: Who we've shared your data with

14.2 Correction and Updating

• Data Accuracy: Right to correct inaccurate personal data

• Completeness: Right to complete incomplete data

• Medical Records: Right to add clarifications to medical records

• Urgent Updates: Expedited processing for medically relevant corrections

14.3 Deletion Rights

• Right to Erasure: Deletion of personal data under certain circumstances

• Medical Records: Subject to legal retention requirements

• Research Data: May be anonymized rather than deleted

• Active Treatments: Deletion may be delayed for ongoing medical care

14.4 Processing Restrictions

• Temporary Restriction: Pause processing while disputes are resolved

• Selective Restriction: Limit processing to specific purposes

• Medical Continuity: Essential medical services may continue

• Legal Obligations: Processing may continue where legally required

14.5 Data Portability

• Format: Machine-readable format for personal data

• Medical Records: Standard healthcare formats (HL7 FHIR, DICOM)

• Direct Transfer: To another healthcare provider where feasible

• Scope: Limited to data provided directly by you

14.6 Objection Rights

• Direct Marketing: Absolute right to opt-out

• Processing Purposes: Right to object to specific processing activities

• Research Participation: Right to withdraw from research studies

• AI Processing: Right to request human-only analysis

14.7 Automated Decision-Making

• Human Review: Right to human intervention in automated decisions

• Explanation: Right to understand the logic of automated processing

• Challenge: Right to contest automated decisions

• Alternative Processing: Right to request manual processing

15.1 How to Make Requests

Email: info@digidxdoc.com

Postal Address: DigiDxDoc Health Solutions Private Limited, Attention: Data Protection Officer
[3rd floor, 196/A, 4th Cross Rd, KHB Colony, 5th Block, Koramangala, Bangalore, Karnataka 560095 ]

Phone: 1800 8899 868

15.2 Request Requirements

• Identity Verification: Government-issued ID or equivalent

• Specific Request: Clear description of the right you wish to exercise

• Relevant Information: Case numbers, dates, or other identifying information

• Medical Proxy: Authorization for representatives or family members

15.3 Response Timeframes

• Standard Requests: 30 days from receipt of valid request

• Complex Requests: May be extended by 60 days with notification

• Urgent Medical Requests: Within 48 hours where medically necessary

• Free of Charge: No fee for reasonable requests

15.4 Request Limitations

We may decline requests that are:

• Manifestly unfounded or excessive

• Prohibited by law or regulation

• Inconsistent with ongoing medical treatment

• Technically impossible to fulfil

16.1 Age Limitations

Our services are not intended for children under 13 years of age. We do not knowingly collect personal data from children under 13 without parental consent.

16.2 Pediatric Medical Services

For medical services involving minors:

• Parental Consent: Required for children under 18 (or local age of majority)

• Mature Minor Doctrine: Applied where legally recognized

• Guardian Authorization: For children under legal guardianship

• Emergency Treatment: Vital interests protection for urgent medical care

16.3 Parental Rights

Parents and legal guardians have the right to:

• Access their child's medical information

• Request correction of inaccurate data

• Withdraw consent for non-essential services

• Receive copies of privacy notices and consents

17.1 Incident Response

In the event of a data breach:

• Internal Assessment: Immediate risk evaluation and containment

• Regulatory Notification: Within 72 hours to relevant authorities

• Individual Notification: When high risk to rights and freedoms

• Remedial Actions: Steps to mitigate potential harm

17.2 Notification Content

Breach notifications will include:

• Nature of Breach: Types of data involved and circumstances

• Potential Impact: Likely consequences for affected individuals

• Measures Taken: Steps to address the breach and prevent recurrence

• Contact Information: How to get more information and assistance

17.3 High-Risk Scenarios

We will notify individuals directly when breaches involve:

• Sensitive health data

• Financial information

• Identity theft risk

• Potential physical harm

• Discrimination risk

18.1 Contact Information

Data Protection Officer, DigiDxDoc Health Solutions Private Limited

Email: dpo@digidxdoc.com

18.2 DPO Responsibilities

Our DPO is responsible for:

• Privacy Compliance: Monitoring adherence to privacy laws

• Training Programs: Staff education on data protection

• Impact Assessments: Conducting privacy impact assessments

• Stakeholder Communication: Liaison with regulators and individuals

18.3 Independent Authority

Our Data Protection Officer operates independently and reports directly to senior management, ensuring unbiased privacy oversight.

19.1 Complaint Rights

You have the right to lodge complaints with relevant supervisory authorities:

• European Union: Your local Data Protection Authority

• United States: Department of Health and Human Services (HIPAA complaints)

• Other Jurisdictions: Local privacy commissioners or data protection authorities

19.2 Complaint Process

Before filing complaints with supervisory authorities, we encourage you to contact us directly so we can address your concerns promptly.

21.1 System Development

We integrate privacy considerations into:

• Product Design: Privacy-friendly default settings

• System Architecture: Data minimization and purpose limitation

• Feature Development: Privacy impact assessments for new features

• Third-Party Integration: Privacy evaluation of all integrations

21.2 Ongoing Monitoring

• Regular Audits: Annual privacy compliance reviews

• Risk Assessments: Continuous evaluation of privacy risks

• Training Updates: Regular staff training on privacy requirements

• Policy Reviews: Annual review and update of privacy policies

22.1 Telepathology Services

Additional Considerations:

• Real-time video consultations may be recorded for quality assurance

• Digital slides may be stored for comparative analysis

• Cross-jurisdictional consultations subject to additional safeguards

22.2 AI-Powered Diagnostics

Additional Considerations:

• AI model training may use anonymized historical data

• Performance monitoring may involve statistical analysis

• Updates to AI models may affect processing methods

22.3 Research and Clinical Trials

Additional Considerations:

• Extended retention periods for regulatory compliance

• Potential publication of anonymized results

• International collaboration may involve data transfers

22.4 Biopharma Services

Additional Considerations:

• Strict confidentiality due to proprietary research

• Regulatory reporting requirements

• Long-term follow-up may be required

23.1 Notification Process

We will notify you of significant changes through:

• Email Notification: To registered users

• Website Notice: Prominent display on our website

• Service Notifications: In-app or portal notifications

• Direct Mail: For material changes affecting your rights

23.2 Effective Date

Changes become effective 30 days after notification, unless:

• Legal Requirements: Immediate compliance required

• Enhanced Protections: Beneficial changes may be implemented immediately

• User Consent: Additional consent required for expanded processing

24.1 General Inquiries

DigiDxDoc Health Solutions Private Limited

Website: www.digidxdoc.com

Email: info@digidxdoc.com

Phone: 1800 8899 868

24.2 Privacy-Specific Contacts

Privacy Questions: privacy@digidxdoc.com

Data Protection Officer: dpo@digidxdoc.com

Security Issues: security@digidxdoc.com

Patient Portal Support: support@digidxdoc.com