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Patient Compass Suite®

Data-Processing Agreement and Information-Governance Note

Schedule to the Tenant Licence Agreement — standard form

This is the schedule your practice acknowledges during onboarding: it states what the suite does and does not process, who the sub-processors are, and what each side undertakes. It is published here in full so your practice manager can read it before anyone signs. The version signed with your agreements is the binding text.

The licence itself is on the terms page; how this website handles data is covered by our privacy notice.

Incorporated as a schedule to the Tenant Licence Agreement signed in this onboarding pack and referenced by the clinician agreement signed alongside it. It is the Data-Processing Agreement the Master Terms (§11.1) incorporate: §6 sets the processor terms UK GDPR Article 28(3) requires. It also states, in one place, the Hard Constraints and why the data-protection surface is deliberately tiny. Provider: GGO Systems Limited (ICO registration ZC174006).


1. The core posture: no intentional patient-identifying data collection

As a matter of fixed design, the suite:

1. Does not intentionally collect patient-identifying health information. No patient name, email, date of birth, NHS number, MRN or other direct patient identifier is requested or stored by the patient-facing products.

2. Does not create patient accounts or profiles. No patient logins, no email capture, no behavioural profiling, no re-identifying analytics.

3. Never authenticates a patient. Patient-facing products (Polaris, The Compass) are anonymous. This principle is absolute.

4. Uses no advertising trackers, cross-site tracking, or behavioural profiling. Patient-facing apps use privacy-preserving, cookieless aggregate analytics (Plausible) only.

5. Contains no clinical decision logic. The suite presents information; it does not advise, triage, or recommend.

Technical telemetry, access-control tokens, IP addresses in infrastructure logs and procedure-specific links may create contextual privacy sensitivity even where they do not identify a patient by name. They must be minimised, retained only as needed for security/operations, and never used to identify patients.

2. The only credentialled surfaces

The "no authentication" rule is relaxed only for clinician / staff identity, and only on non-patient-facing surfaces:

The limited personal data processed is therefore clinician / staff / business-contact data — not patient data.

3. Data-protection analysis (summary)

4. The MVP gap — declared openly

Because there is no patient authentication and no patient identifier, the suite cannot prove an individual patient accessed a given asset. The litigation-defensibility narrative is population-level (Montgomery framing). This is a known, declared limitation, not a hidden defect, acknowledged by the Tenant at intake.

5. Audit trail (what is recorded)

Per content item: sourceDocumentType + sourceVersionReflected + lastSyncedAgainstSource; per pathway: approvalAuthority; Sanity edit history; and the immutable `clinicalSignoff` audit. This is clinician/staff governance metadata, not patient-identifying data. This Agreement itself is recorded with an electronic-signature audit (typed name, timestamp, document hash, IP, user-agent).

6. Processor terms (UK GDPR Article 28(3))

For the clinician and staff personal data described in §2, the Tenant is the controller and the Provider is the processor. This section is the written contract that UK GDPR Article 28(3) requires. It is signed with this pack as the Data-Processing Agreement the Master Terms incorporate; no separate data-processing agreement is needed.

6.1 Subject matter and duration. The processing of the Tenant's staff identity and business-contact data for the life of the licence (the Tenant Licence Agreement and any schedule that replaces or extends part of it), and thereafter only for the audit retention the Master Terms require.

6.2 Nature and purpose. Authenticating the Tenant's clinicians and staff in The Helm; operating the Deployment, including the clinical sign-off audit trail, support records and platform-security logs; and forming, storing and keeping these agreements.

6.3 Types of personal data and categories of data subject. Clinician and staff names, work email addresses, professional registration numbers, roles, and business-contact details, with the sign-in and audit metadata that accompanies them (timestamps, IP address, user agent). Data subjects: the Tenant's clinicians and staff — never patients.

6.4 The Provider's obligations as processor. The Provider will:

6.5 International transfers. Clerk (Clerk, Inc.) and Notion (Notion Labs, Inc.) process data in the USA. The Provider relies on the UK International Data Transfer Addendum to the EU Standard Contractual Clauses with those sub-processors and completes a transfer risk assessment for each. No patient data is transferred, because none is collected.

7. Tenant obligations


This note states the position for the MVP. Any change to §1 is a written variation under the Master Terms (clause 12.3), not an operational tweak.