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Global Ethical AI Governance Framework

Clinicians Check Global Group

Effective Date: 27/05/2025

Version: 1.0

Owner: AI Ethics & Compliance Council

1. Introduction

1.1 This document outlines the jurisdictional mapping of privacy laws, data transfer responsibilities, and legal obligations related to data processing activities relevant to CliniciansCheck. 1.2 CliniciansCheck operates internationally and recognises the privacy regimes across multiple jurisdictions. This map is intended to demonstrate our commitment to legal compliance across all territories where we operate or engage users. 1.3 We acknowledge that global data protection laws are constantly evolving. This page is reviewed regularly to ensure up-to-date accuracy and jurisdictional alignment.

2. General Operating Principles

2.1 CliniciansCheck does not store, transmit, or process sensitive patient data, including mental health disclosures or medical records, within its internal servers or systems. 2.2 Users may choose to submit data to secure, externally managed environments facilitated by CliniciansCheck. However, these third-party tools operate independently and are configured to meet local regulatory and security obligations, including HIPAA, GDPR, and similar global standards. 2.3 Free-text fields within user-controlled areas of the platform may contain unsolicited health-related disclosures. CliniciansCheck does not monitor, process, or medically interpret this content and explicitly disclaims any responsibility for health data voluntarily entered into open fields by users. 2.4 Where patients choose to upload or store data, they are always directed to secure third-party environments that are encrypted, access-controlled, and externally hosted. These providers operate within frameworks that meet national and international legal standards. 2.5 This design ensures CliniciansCheck does not process or control personal health information (PHI), thereby removing the need for internal medical records infrastructure and reducing jurisdictional liability exposure.

3. Jurisdictional Compliance Mapping

3.1 United Kingdom: Compliant with the UK GDPR and governed by the Information Commissioner’s Office (ICO). 3.2 European Union/EEA: Aligned with EU GDPR through lawful data minimisation practices and outsourcing of sensitive processing to compliant third-party systems. 3.3 United States: HIPAA-aligned operations are maintained through the use of external, certified platforms for any health-related user interaction. FTC and state-level privacy expectations are acknowledged. 3.4 Canada: Compliance aligns with PIPEDA and provincial healthcare regulations via the external processing model. 3.5 Australia: Practices adhere to the Australian Privacy Principles (APPs) under the Office of the Australian Information Commissioner (OAIC). 3.6 Singapore: Alignment with the Personal Data Protection Act (PDPA), as monitored by the Personal Data Protection Commission. 3.7 India: Structured to reflect obligations under the Digital Personal Data Protection (DPDP) Act, 2023. 3.8 Brazil: Adherence to the General Data Protection Law (LGPD) is assured through avoidance of internal PHI processing. 3.9 Other Jurisdictions: Data practices are adapted in alignment with national privacy laws where required, based on location-specific risk assessments.

4. Data Transfers and Storage

4.1 CliniciansCheck ensures that no direct patient data requiring localisation remains within our platform’s infrastructure. 4.2 Any cross-border transfer activity involving data, such as analytics or usage logs, is conducted on anonymised, non-sensitive records or with adequate safeguards in place. 4.3 Third-party platforms utilised for optional data input and recordkeeping operate under contract with strict data protection, breach response, and jurisdictional controls.

5. Patient Autonomy and Disclaimers

5.1 Users remain in full control of any clinical, personal, or sensitive data they choose to upload or input. 5.2 Patients are directed to use an external secure mechanism to handle records, and CliniciansCheck is not responsible for monitoring or flagging mental health disclosures or medical data entered into their own profile. 5.3 CliniciansCheck disclaims all responsibility for any such free-text or uploaded data inputted outside the bounds of our formally supported process. 5.4 Our role is to provide directional guidance only, not a clinical or regulated data processor function.

6. Enquiries and Complaints

6.1 All regulatory or data protection enquiries should be directed to: operationsteam@clinicianscheck.com 6.2 We will respond to any legitimate authority or regulatory inquiry within the required legal timeframe, as outlined by the applicable jurisdiction. 6.3 Complaints can also be escalated through our dispute mechanism or regulatory notification process as described in related policy pages.

7. Review and Updates

7.1 This policy is subject to periodic review and immediate amendment in the event of legal developments or jurisdictional mandates. 7.2 The current version supersedes all prior versions and is binding as of the effective date.