Intelligent Roster

Compliance & Privacy

Compliance Is Non-Negotiable

We build and operate IRIS to the standards health services expect — Australian Privacy Act, APPs, GDPR where applicable, and a clear boundary: no patient data, ever.

Why this matters for health CTOs

Healthcare technology decisions are scrutinised by risk, legal, and procurement. You need vendors who can articulate their compliance posture, demonstrate controls, and stay within scope — so you’re not left explaining someone else’s overreach. Our commitment is simple: we comply with the frameworks that apply to our product, we don’t handle patient data, and we document how we do it.

Applicable Frameworks

The Frameworks We Meet

We don’t claim certifications we don’t hold. Where we rely on a provider’s certification (Render, AWS), we say so clearly and point to their artefacts.

Framework Scope Our Posture
Privacy Act 1988 (Cth) Australian organisations handling personal information ✓ Compliant
Australian Privacy Principles (APPs) All 13 principles ✓ Implemented
Notifiable Data Breaches (NDB) Scheme Eligible data breaches — Australian organisations ✓ Procedures in place
GDPR EU-based staff (e.g. global teams with EU members) ✓ Compliant — data subject rights and safeguards in place
SOC 2 Type II Infrastructure security, availability, confidentiality Inherited — Render & AWS
ISO/IEC 27001:2022 Information security management Inherited — Render & AWS
💡 On inherited certifications: Where we rely on a provider’s certification, we say so explicitly. Render holds SOC 2 Type II and ISO 27001; AWS holds these plus IRAP-assessed infrastructure on Sydney. We point to their artefacts rather than adopting their certifications as our own.
Data Scope

What We Handle — and What We Don’t

IRIS is a workforce rostering system. We handle staff and scheduling data only. That boundary is deliberate, technically enforced, and it significantly simplifies your compliance picture.

In Scope for IRIS

Workforce Data

  • Staff names and contact details
  • Employment and role data
  • Schedules, shifts, and leave
  • Qualifications and skills
  • Availability preferences
Out of Scope — We Don’t Store or Process

Patient & Sensitive Data

  • Patient identifiers, MRN, date of birth
  • Clinical notes, diagnoses, treatments
  • Health records or My Health Record data
  • Payment card data or Medicare numbers
  • Any other health information as defined by legislation
Framework Applicability

Applicable, Conditional, or Not Applicable

Because IRIS holds workforce data only, several major frameworks simply don’t apply. This is not a loophole — it’s the result of a deliberate design boundary.

Privacy Act & APPs ✓ Applies

Australian organisations handling personal information. Fully compliant; all 13 APPs implemented.

NDB Scheme ✓ Applies

Eligible data breach notification obligations. Procedures are in place.

GDPR Conditional

Applies where your organisation has EU-based staff. Data subject rights and transfer safeguards in place.

My Health Records Act Not Applicable

We don’t interact with My Health Record or store health record data of any kind.

State / Territory Health Acts Not Applicable

We don’t hold “health information” as defined under state and territory health records legislation.

HIPAA Not Applicable

We have assessed HIPAA applicability and determined it does not apply — we don’t process protected health information (PHI).

PCI-DSS Not Applicable

We don’t process, store, or transmit payment card data.

SOC 2 Type II Inherited

Held by Render and AWS. We rely on and reference their certified artefacts.

ISO 27001 Inherited

Held by Render and AWS. We rely on and reference their certified artefacts.

How We Demonstrate It

Built to Answer the Hard Questions

Your risk and procurement teams will ask: who has access, where is data, how is it protected, and what happens if something goes wrong. We’re built to answer all of these.

📋

Privacy Policy

Our Privacy Policy documents what data we collect, how we use it, and your rights under the Australian Privacy Act and GDPR where applicable. Publicly available and kept current.

🔒

Technical Controls

Encryption at rest and in transit, RBAC, SSO, MFA, audit logging, and secure development practices. Documented and verifiable through our infrastructure providers’ certified artefacts.

📝

Data Handling Terms

Clear contractual data handling terms, subprocessor transparency, and defined data retention and deletion obligations. We are clear about what we hold, why, and for how long.

⚙️

Operational Practices

We operate with security and privacy practices including access control, incident response procedures, and periodic reviews. These are ongoing, not one-off exercises.

Global Teams

GDPR and Cross-Border Clarity

If your organisation has EU-based staff, GDPR applies to their personal data. Here’s exactly what we do.

🧑‍⚖️

Data Subject Rights

We support access, rectification, portability, and erasure requests for EU-based staff data — as required under GDPR Articles 15–20.

🌐

International Transfer Safeguards

Where data is transferred internationally, we apply appropriate contractual and technical safeguards. Our data residency page documents where data lives by region.

📌

Lawful Basis & Purpose Limitation

We document lawful basis and purpose limitation for all processing of personal data — a core GDPR requirement we apply globally, not only for EU staff.

🔎

HIPAA — Our Assessment

We have assessed HIPAA applicability. Our conclusion is that HIPAA does not apply to IRIS because we do not process protected health information (PHI). Staff location in the US does not change that. We’re happy to explain this assessment in procurement discussions.

Continuous, Not One-Off

Compliance Is How We Run the Product

Not a single audit, not a checkbox. Security and privacy are part of design and operations — ongoing by default.

Ongoing

Security and privacy are designed into the product from the start — not retrofitted. Every feature and change goes through the same security lens.

Reviewed

We review policies and controls periodically and after significant changes to the product, infrastructure, or regulatory environment.

Transparent

Scope (workforce only), regions (Singapore / AWS Sydney), and certifications (ours and our providers’) are all documented clearly — not buried in fine print.

At a Glance

What Defines Our Compliance Posture

🇦🇺

Australian Frameworks

Privacy Act, all 13 APPs, and NDB Scheme — documented and implemented.

🌍

Global-Ready

GDPR for EU staff. HIPAA assessed — not applicable. No PHI means no PHI obligations.

🚫

No Patient Data

Technically enforced. Simplifies scope — no MHR, state health acts, or HIPAA.

📋

Demonstrable

Privacy policy, technical controls, data handling terms, and provider certifications.

Need More Detail?

Let’s Have the Compliance Conversation

See our Privacy and Security pages for full detail — or contact us directly for procurement, risk, and assurance discussions.