Trust · Australia

Australian Privacy Act: programme in progress.

Every health service provider in Australia is covered by the Privacy Act and the Australian Privacy Principles, whatever its size, and by the Notifiable Data Breaches (NDB) scheme. Our server is in the United States, which is a cross-border disclosure under APP 8. The product has the safeguards below. The contracts, local hosting and the NDB workflow are still open.

Send us your Privacy Act questions The trust centre

Status as of 24 September 2026
No compliance claimed
Every control names its module

At a glance

Law: the Privacy Act 1988 and the Notifiable Data Breaches scheme
Region: MedAppz Australia
Data stored in: Boston, United States · Hostinger VPS
What we hold: Programme in progress
Our items in place: 1 of 6
Status as of: 24 September 2026

Status

Where we stand, as of 24 September 2026

This covers the Privacy Act 1988 and the Notifiable Data Breaches scheme. MedAppz does not claim compliance with it or any certification under it. This is a programme in progress, and this table is where it stands. Records are stored on one server: Boston, United States · Hostinger VPS. Using it is a cross-border disclosure under APP 8.

Item	Status	Note (2026-09-24)
Contract covering APP 8 cross-border disclosure	Not started	The server is in the US. No Australian contract terms are published yet.
Australian hosting region	Not started	There is one server, in the US. No Australian region is set up.
Sub-processor agreements	Not started	We hold no signed agreement with any sub-processor yet: not the host, not the AI or speech vendors, not the SMS, email or WhatsApp providers.
NDB scheme: 30-day assessment and notice to the OAIC	Not started	The breach register tracks Indian deadlines only. The NDB assessment clock is not built.
My Health Record connection	Not started	Not connected.
Audit trail, emergency access, access reviews, backups	In place	Listed below, each with the module that does it.

In place

In place in the product today

Each of these runs in the product now. The line under each one names the part of the law it relates to. That is a pointer for your own review, not a claim that the clause is met.

An audit trail that cannot be editedRecord opens, searches and exports are written once: who, when, from where, under which permission. The log is append-only by database trigger and hash-chained day by day; the chain is re-verified nightly.Audit schema and AuditLens · Security of personal information — APP 11

One clinic cannot read another’s rowsRow-level security on every tenant table, bound to the transaction. The account the application runs as cannot switch it off.Database row-level security · Security of personal information — APP 11

Emergency access that expires and is reviewedBreak-glass access needs a written reason, lasts at most four hours (a database constraint), and lands on a review queue.BreakGlass · Security of personal information — APP 11

Consent records, by notice versionMessages are gated on the consent notice the patient accepted, by version, at the moment of sending. Withdrawal cancels what is queued.ConsentVault and the consent service · Use or disclosure — APP 6

Access reviews with two-person revocationThe Security Centre runs dated access-review campaigns over privileged grants (full patient data, money, platform, emergency access). A challenge raises a two-person approval; a campaign cannot close with unread items.Security Centre · Open and transparent management — APP 1

Strong sign-in and short sessionsArgon2id password hashing, lockout after five failures, optional or organisation-required app-based two-factor, 15-minute access tokens with rotating refresh tokens, and a five-minute idle-out on shared devices.Identity

Encryption in transit, and sealed credentialsTLS on every connection, with certificates renewed automatically. Keys and passwords a clinic gives us are sealed with AES-256-GCM, bound to the organisation, and never shown back.TLS and the secrets envelope

Nightly verified backups, with a rehearsed restoreThe database and files are dumped every night and each dump is checked before the run counts as a success. A full restore was rehearsed on 3 September 2026.ops/backup.sh

Exports are whitelisted and recordedOnly listed views can be exported, each needs its permission, and each export is recorded with its row count and data classes.Exports · Use or disclosure — APP 6

AI you can switch off, or send redactedOne setting per organisation: off, redacted (the default) or full. Redacted strips the name, date of birth, hospital number, phone and email before the request leaves our server. A named person accepts every draft.AI governance

Your side

What you would need to do

Keep your own APP privacy policy, and tell patients their records may be held in the United States.
Take reasonable steps under APP 8 before disclosing to an overseas recipient, which starts with a contract we have not yet signed.
Have your own data breach response plan for the NDB scheme.
Do not move real patient records in until the contract is in place.

This page describes our product. It is not legal advice; take your own advice on how the law applies to your practice.

Sub-processors

Sub-processors and where they are

Every outside service the product can send data to, where it processes it, and whether an agreement is signed. The list is generated from the register the product itself reads, the same one the Trust Centre shows.

The Trust Centre’s list →

Service	Location	Agreement
Hostinger — The rented server the database, the application and the uploaded files run on	One rented region	None signed yet
S3-compatible object storage — Where uploaded files and documents live when object storage is switched on	The bucket region the deployment configured	None signed yet
Anthropic — AI drafting and answering	United States	None signed yet
OpenAI — AI drafting and answering	United States	None signed yet
Google (Gemini) — AI drafting and answering	United States	None signed yet
NVIDIA NIM — AI drafting and answering	United States	None signed yet
The configured speech-to-text service — Turning a consultation recording into a transcript	Wherever SPEECH_API_BASE_URL points — api.openai.com (United States) unless changed	None signed yet
The clinic’s own Jitsi server — Carrying the live audio and video of a video visit	Wherever the clinic hosts it	None signed yet
Resend — Sending email	United States / European Union	None signed yet
MSG91 — Sending SMS	India	None signed yet
Meta (WhatsApp Business) — Sending WhatsApp messages through the official API	Meta’s global network	None signed yet
The clinic’s paired WhatsApp number — Sending WhatsApp messages from the clinic’s own handset session	Meta’s global network, through the clinic’s own number	None signed yet
The common WhatsApp assistant number — Staff asking the assistant from their own WhatsApp, and patients who write to the common number	Meta’s global network, through the platform’s paired number	None signed yet
Google (Firebase Cloud Messaging) — Delivering push notifications to a phone	Google’s global network	None signed yet
Razorpay — Taking a payment online, and holding a standing UPI Autopay or e-mandate authorisation	India	None signed yet
PhonePe — Taking a payment online	India	None signed yet
Stripe — Taking a payment online	United States	None signed yet
Pine Labs — Taking a card payment on the counter terminal	India	None signed yet
Google Sheets — Receiving a scheduled export	Google’s global network	None signed yet
Google Business Profile and Meta — Reading reviews and publishing the clinic’s replies	Google and Meta’s global networks	None signed yet
The clinic’s own mail server — The mailbox MedAppz proxies rather than copies	Wherever the clinic’s mail is hosted	None signed yet
The hospital’s own GST Suvidha Provider — Registering the hospital’s own patient invoices with the Invoice Registration Portal	India	None signed yet
The clinic’s own Tally server — Receiving the accounting export, and answering which vouchers it took	Wherever the clinic runs Tally	None signed yet
National Health Authority (ABDM gateway) — India’s national health exchange: linking care contexts and sending records a patient consented to	India (NHA)	None signed yet
A database the clinic brings — A destination the clinic asked the product to write to	Wherever the clinic hosts it	None signed yet

Questions

Privacy Act, briefly

Where does MedAppz stand on Privacy Act today?

MedAppz does not claim compliance with Privacy Act or any certification under it. As of 24 September 2026, 1 of the 6 items on our side are in place and 5 are still open; the table above lists each one.

Where are the records stored?

Records are stored on one server: Boston, United States · Hostinger VPS. Using it is a cross-border disclosure under APP 8.

What would our practice need to do?

Keep your own APP privacy policy, and tell patients their records may be held in the United States. Take reasonable steps under APP 8 before disclosing to an overseas recipient, which starts with a contract we have not yet signed. Have your own data breach response plan for the NDB scheme. Do not move real patient records in until the contract is in place.

Send us your Privacy Act questions

Your security questionnaire is longer than this page. Leave a number and we will answer it line by line, including where the answer is “not yet”.