Privacy notice
How Health Vault looks after your information
This notice explains, in plain language, what personal and health information Health Vault collects, why, who can see it, how we protect it and what your rights are. Health Vault is designed and operated in line with POPIA, the Protection of Personal Information Act, 2013.
1. Who we are
Health Vault is a personal health record service run by Kiros Healthcare in South Africa. Kiros Healthcare is the responsible party for the personal information described here. It decides why and how that information is processed.
This notice applies to everyone who uses Health Vault: patients, parents and guardians who keep records for their children, and health professionals who register to view records that patients share with them.
2. What we collect
If you are a patient
- Account details: your full name, email address, phone number (optional), password (stored only in scrambled, hashed form) and your South African ID number. Your date of birth is worked out from your ID number. If you add them, we also keep your medical aid name and number.
- Lab reports and results: the pathology reports you upload (PDF or photo), and the results recorded from them: test names, values, units, reference ranges, flags, test dates, the lab's name and a plain-English explanation of each result.
- Scans and other tests: the details you enter about X-rays, ultrasounds, ECGs and similar tests (type of test, date, facility, referring doctor, findings, outcome, follow-up date and notes), and any report file you attach.
- Documents: files you upload, such as prescriptions, referral letters, vaccination certificates and photos of the Road to Health booklet.
- Children's records: for each child you add, their name, ID number or date of birth, your relationship to them, their growth measurements, vaccinations and developmental milestones.
- Sharing choices: which health professionals you have shared your records with, requests they have made, and when access was given, declined or stopped.
- Connected practices: if you connect a practice such as TEAM 24/7, a record of that connection (the practice, its reference for you, and when it was made or ended) and the documents the practice sends to your vault.
- Your consent: the date and time you agreed to Health Vault storing and processing your health information.
If you are a health professional
- Your full name, email address, phone number, HPCSA registration number, qualification or specialty, practice name, password (hashed) and whether your registration has been approved.
For everyone
- Sign-in and security information: the cookies that keep you signed in, and records of emails the site sends. Our hosting provider keeps standard server logs, which include IP addresses, browser type and the pages requested. Administrator accounts also hold two-factor authentication settings.
3. Why we use it
- To create and run your account and confirm who you are.
- To store your health records and show them back to you as results, charts, summaries and downloadable PDFs.
- To share your records with the health professionals you choose, and to receive documents from practices you connect.
- To let parents and guardians keep records for their children, and to hand those records over as children grow up.
- To check that health professionals are registered before they can use the service.
- To send you service emails, such as access requests, approvals and password resets.
- To keep the service secure, prevent misuse and meet our legal obligations.
We do not sell your information, use it for advertising, or share it with medical schemes, employers or insurers.
4. Our lawful basis
Health information is "special personal information" under POPIA, and it gets extra protection. We process it on these grounds:
- Your consent. You give it when you create your account, and you can withdraw it at any time (see section 11). Parents and guardians give consent for their children.
- Health care under a duty of confidentiality. When you share your records with a health professional, or a practice sends you documents, that professional or practice handles the information as part of your care and is bound by professional confidentiality.
- Providing the service you asked for, and meeting our legal obligations.
5. Who can see your information
| Who | What they can do |
|---|---|
| You | See, add, download and delete your own records. |
| A parent or guardian | Manage the records of a child they have added, until the child turns 18. |
| The Kiros Healthcare clinical team | A small number of members of the Kiros Healthcare clinical team, who are registered health professionals bound by professional confidentiality, can view a read-only summary of all patient records. They use this access to oversee the service and to support patients. |
| Every other health professional | Sees a read-only summary of your results, scans and documents only when you share your records with them. Access ends as soon as you stop sharing. |
| Practices you connect (such as TEAM 24/7) | Add documents to your vault. A connected practice can never open, read or download anything in your vault. The connection only works with a one-time code from your vault, and your ID number must match on both sides. You can disconnect at any time. |
| Kiros Healthcare administrators | A small number of authorised people can reach the system to support you, fix problems and keep it secure. They are bound by confidentiality and do not browse records without a reason. |
6. Service providers we use
We use a few trusted providers to run Health Vault. They may only use your information to provide their service to us.
- Web hosting in South Africa for the website, database and uploaded files.
- Email delivery through our own Kiros Healthcare mail server, for service emails.
- Encrypted backups on Google Drive. Backups are encrypted before they leave our server, and Google's servers may be outside South Africa.
- Reading your lab reports happens on our own servers in South Africa. When you upload a report, it is read by software we built and run ourselves. Digital PDFs are read on the same South African server that holds your vault, and photos or scans are read on our own server in Samrand, South Africa, over an encrypted connection that only our server may use. No part of your report, and no image of it, is sent to any outside service, and nothing leaves South Africa. Page images and the text read from them are deleted as soon as your results are saved.
- Website resources: the public pages load fonts from Google Fonts, and the vault's charts load a charting library from the jsDelivr network. Your browser connects to those services to download these files, which shares your IP address with them. No health information is sent.
Where information goes outside South Africa, we send no more than the service needs, and we rely either on your consent or on the provider being bound to protect it, as POPIA allows.
7. Where your information is stored
Your account and health records are stored on servers in South Africa. Encrypted backup copies are kept on Google Drive, as described above.
8. How we protect it
- All connections to Health Vault are encrypted (HTTPS).
- ID numbers and medical aid numbers are encrypted in the database.
- Records and files are only given to the signed-in owner, a guardian, the Kiros Healthcare clinical team described in section 5, or a health professional the patient has shared with. Every request is checked.
- Health professional accounts are checked and approved by hand before they work.
- Practice connections need a one-time code the patient requests, and every message from a practice is digitally signed and checked.
- Administrator accounts must use two-factor authentication, and the administration login is not at the usual WordPress address.
- We keep dated records of consent, sharing and practice connections, and back up the system twice a day in encrypted form.
No system is perfectly secure. If a breach puts your information at risk, we will tell you and the Information Regulator as POPIA requires.
9. How long we keep it
- We keep your records for as long as your account is open, because a lifelong record is the point of Health Vault.
- You can delete all your health records from inside your vault. This removes your lab reports, results, scans, documents, children's tracker entries and sharing permissions, including the files themselves.
- To close your login and remove your account details (name, email, phone and ID number) as well, email us (see section 14) and we will do it.
- Backups are replaced on a rolling basis, so deleted information drops out of them within a few days.
- We may keep a minimal record for longer where the law requires it, for example proof of consent.
10. Children
Children cannot open their own Health Vault account. A parent or guardian adds them, and each child's record is kept in the child's own name, not inside the parent's record.
- From age 12, South African law lets a child consent to their own medical treatment. We send the guardian a notice when a child reaches that age.
- A guardian can give a child their own login, using the child's own email address.
- When a child turns 18, the guardian's access ends automatically. The records stay with the young adult.
- Removing a child from your account does not delete the child's records.
11. Your rights
Under POPIA you have the right to:
- Access the personal information we hold about you. Most of it is already visible in your vault.
- Correct information that is wrong or out of date.
- Delete your information, or ask us to.
- Object to how we process your information, and withdraw your consent at any time. Withdrawing consent means we can no longer keep your health records, so we will delete them.
- Complain to the Information Regulator if you are unhappy with how we handle your information.
To use any of these rights, contact us as shown in section 14. We may ask you to confirm your identity first, and we will reply within a reasonable time.
13. Changes to this notice
We may update this notice when the service changes or the law requires it. The effective date at the top will always show the current version. If a change affects how we use your health information, we will tell you by email or in your vault before it takes effect.
14. Contact us
For privacy questions, requests or complaints, please contact the Kiros Healthcare Information Officer.