Privacy Notice

ClarityQ Ltd is a clinical analytics platform registered in England and Wales (Company No. 17072041), with its registered address at 71-75 Shelton Street, London, WC2H 9JQ. ODS Code: O3E4P.

For data protection enquiries, contact: info@clarityq.co.uk

ClarityQ processes data under the following lawful bases:

• Article 6(1)(b) — Performance of a contract (service delivery to subscribing practices)
• Article 6(1)(f) — Legitimate interests (platform security, audit logging, fraud prevention)
• Article 9(2)(h) — Health data processing for the provision of health care (where applicable)

The Data Controller (GP practice) relies on their own lawful basis for collecting and sharing data with ClarityQ, typically under Article 6(1)(e) — Public task, or Article 9(2)(h) — Health care provision.

Clinical analytics data (pseudonymised): Aggregated, population-level health indicators extracted from EMIS Web or SystmOne. No direct patient identifiers are processed.

User account data: Name, email address, role, organisation, login timestamps, and audit trail of platform actions.

Clinical Scribe transcriptions: Voice-to-text output only. Audio is processed ephemerally and never stored. Only the transcribed text is retained for the clinician to review and copy.

Triage Co-pilot input: Symptom descriptions entered by clinicians. Automated PII detection strips any patient-identifiable information (NHS numbers, names, postcodes, dates of birth, email addresses, phone numbers) before processing.

ClarityQ implements automated PII detection and stripping on all free-text input fields. The following identifiers are automatically detected and blocked:

• NHS numbers (10-digit format)
• UK postcodes
• Dates of birth
• Email addresses
• UK phone numbers
• Patient names (via pattern matching)

This operates at both the client-side (immediate user feedback) and server-side (API-level blocking) to ensure defence in depth.

ClarityQ shares data only with the following sub-processors, all under Data Processing Agreements. AWS stores pseudonymised NHS patient data; AccuRx and Docman Connect transiently transfer patient messages/clinical letters (not stored by ClarityQ); all other sub-processors handle no NHS patient data:

• Amazon Web Services (AWS) — Cloud infrastructure, eu-west-2 (London). Processes pseudonymised NHS patient data. ISO 27001, Cyber Essentials Plus certified.
• Netlify — Frontend hosting and CDN delivery (no patient data).
• Stripe — Payment processing (PCI DSS Level 1 compliant; billing data only).
• Microsoft 365 & Google Workspace — Staff email, documents and collaboration (no patient data).
• GitHub — Source-code version control (no personal data).
• Cloudflare — DNS, DDoS protection and CDN (request metadata only).
• AccuRx and One Advanced (Docman Connect) — Patient messaging and clinical-letter transfer respectively; data is transient and not stored by ClarityQ. Formal DPAs are being finalised.

All NHS patient data is processed and stored within the UK (AWS eu-west-2, London region). No international transfers of NHS patient data take place. The only sub-processor located outside the UK is GitHub (USA, source code only), covered by Standard Contractual Clauses.

ClarityQ will not share personal data with any third party for marketing purposes.

ClarityQ implements comprehensive security measures:

• Encryption: AES-256 at rest (AWS KMS), TLS 1.2+ in transit
• Authentication: Multi-factor authentication (MFA) mandatory for all users
• Access control: Role-based access control (RBAC) with admin-only restrictions on sensitive pages
• Monitoring: AWS GuardDuty, Security Hub, CloudTrail, CloudWatch alarms
• Content Security Policy: CSP headers enforced via Netlify edge functions
• Certifications: Cyber Essentials certified, DSPT aligned, DCB0129 compliant

As a data subject, you have the following rights:

• Right of access (Article 15) — Request a copy of your personal data
• Right to rectification (Article 16) — Request correction of inaccurate data
• Right to erasure (Article 17) — Request deletion of your data (subject to retention obligations)
• Right to restrict processing (Article 18) — Request limitation of processing
• Right to data portability (Article 20) — Receive your data in a structured format
• Right to object (Article 21) — Object to processing based on legitimate interests

For patient data, rights requests should be directed to the Data Controller (your GP practice), as ClarityQ processes this data on their behalf.

For platform user data, contact info@clarityq.co.uk. We will respond within 30 days.

If you are dissatisfied with how your data is handled, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

• Website: ico.org.uk
• Telephone: 0303 123 1113
• Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

We encourage you to contact us first at info@clarityq.co.uk so we can try to resolve any concerns directly.