Data Protection Policy

This policy applies to all personal data processed through PodiaScan. Each clinic is the controller of its patient records; GD Consultants is the processor for those records and the controller of user account and billing data. A data processing agreement governs the processor relationship.

• Lawfulness, fairness and transparency in every processing activity.
• Purpose limitation — clinical data is used only to deliver and support the service.
• Data minimisation — we collect only what a foot thermometry record requires.
• Accuracy — clinicians can correct patient details and scan records.
• Storage limitation — data is deleted or returned when no longer required.
• Integrity and confidentiality — enforced technically, not only by policy.
• Accountability — decisions and safeguards are documented.

Plantar temperature readings, risk levels and alert states are health data. They are visible only to authenticated members of the clinic that recorded them, are never used for profiling, marketing or model training, and are not disclosed to third parties except the infrastructure providers required to run the service.

• Authentication is required for every clinical screen and data request.
• Row-level security scopes every read and write to the signed-in user's clinic, so cross-tenant access is blocked at the database, not just in the interface.
• Roles are held in a dedicated roles table and checked server-side.
• Encryption in transit (TLS) and at rest by our infrastructure providers.
• Passwords are hashed and screened against known-breached password lists.
• Least-privilege access for administrators and periodic access review.

We use a limited set of sub-processors for hosting, database, authentication and email. Each is contractually bound to equivalent protection. Where any processing occurs outside the EEA, transfers rely on Standard Contractual Clauses or an adequacy decision.

Clinical records are retained under the clinic's own retention schedule. On written instruction, or within a reasonable period after a clinic leaves, its data is exported and then permanently deleted from live systems, with backups aging out on their normal cycle.

Requests from patients are handled by the treating clinic; we assist the clinic in responding within statutory time limits. Requests about a user account can be sent directly to us.

Suspected breaches must be reported to privacy@podiascan.com without delay. We investigate, contain and record the incident, notify affected controllers without undue delay, and support any notification to the Data Protection Commission or affected individuals.

This policy is reviewed at least annually and whenever the service changes materially.