Privacy policy

This policy explains how [LEGAL ENTITY NAME] (“we”, “us”, “FocusMD”) handles personal information, including health information, when you use the FocusMD service. FocusMD is a clinical documentation system used by hospitals, so the information we process is frequently sensitive health information.

1. Who this policy applies to

There are two groups whose information we handle:

• Users — doctors, nurses, pharmacists, billing executives, hospital administrators and other staff who hold a FocusMD account.
• Patients — people whose records are held by the hospital using FocusMD. We process patient information on behalf of, and at the direction of, that hospital. The hospital is the patient's health information provider and controls what is recorded and shared.

2. What we collect

• Account data: name, work email address, role, hospital affiliation, hashed password, and professional registration details where the role requires them (for example, HPR verification for prescribers).
• Clinical data: audio of the consultation (processed, not retained), the generated transcript, draft and signed clinical notes, suggested and accepted ICD-10 codes, prescriptions issued and dispensed, and vitals.
• Billing data: charges raised, concessions granted with their reason and approver, insurance coverage details entered at the counter, and payment records.
• Consent and exchange data: ABDM consent requests and decisions, the purpose and health information types covered, records fetched from or pushed to other providers, and the validation checks applied to each exchange.
• Usage and audit data: records of actions taken in the system — who viewed, created, edited, signed, dispensed or exported a record, and when — plus service logs.

3. Health information and the law

Clinical records in India are sensitive personal information. We handle them in line with the Digital Personal Data Protection Act, 2023 and its rules, the ABDM's health information exchange framework, and the retention obligations that apply to clinical records under Indian law.

Two consequences are worth stating plainly. First, a signed clinical record generally cannot be erased on request, because the law requires it to be retained for a statutory period. Where a patient asks for erasure, we refuse explicitly, record the specific reason, and send that to the patient — a request is never silently ignored. Second, consent to share with other providers is a separate decision from the hospital's own record-keeping, and FocusMD treats them separately.

4. ABDM consent

Where a hospital enables ABDM exchange, consent is requested on the patient's own device through the Aadhaar OTP or Health ID flow. FocusMD cannot consent on a patient's behalf. Consent is requested per purpose and per health information type, so a patient may grant one category and refuse another; we record what was actually granted, not what was asked for.

Records fetched from other providers are displayed as read-only and labelled with their source hospital and the time of the fetch. They are never presented as though this hospital recorded them. Withdrawing consent stops all future sharing immediately; records already shared with other providers cannot be recalled, and patients are told this at the point of withdrawal.

5. How we use information

• To generate transcripts and draft clinical notes for review by the treating prescriber.
• To operate, secure and support the service, including audit logging and abuse prevention.
• To exchange records with other providers where the patient has consented.
• To answer data requests from patients under the DPDP Act.
• To communicate with hospital administrators about their accounts.

We do not sell personal information. We do not use consultation content or patient records to train machine-learning models.

6. Speech processing and subprocessors

Audio is transcribed and notes are drafted using OpenAI's API. OpenAI processes this data under API terms that prohibit using customer data to train or improve their models. Other subprocessors include our hosting and database providers ([LIST HOSTING/DATABASE PROVIDERS AND REGIONS]). Patient data is hosted in an Indian data region; hospital records do not leave India. A current list of subprocessors is available on request.

7. Data storage and security

• Data is encrypted in transit (TLS) and at rest.
• Access is role-based and scoped: a pharmacist cannot open a consultation note, and a billing executive cannot sign a clinical record.
• Only HPR-verified prescribers can sign a clinical record; the system refuses the action for anyone else.
• Every action on a record is written to an immutable audit trail.

8. Retention

• Audio: processed and not retained after the session is finalised.
• Transcripts: automatically purged after the hospital's configured retention period (default 90 days).
• Signed clinical records: retained for the statutory period applicable to the record type, and not deleted on erasure request where that retention applies.
• Audit records: retained for the period required for accountability, independent of the clinical record.
• Account data: deleted within [30] days of account closure.

9. Your rights and access

Patients may exercise four rights against the hospital that holds their record: access, correction, erasure, and withdrawal of consent. Requests are handled in the product: identity is verified first, every action is gated on that verification, and the outcome — including a reasoned refusal — is recorded and communicated. Hospital staff can see the status of each request.

Users may access and correct their own account data through the service or by contacting us. You may complain to the Data Protection Board of India if you believe your information has been used in breach of this policy.

10. Contact

Privacy enquiries and data requests: hello@focusmd.org · Postal: [POSTAL ADDRESS]