Privacy Policy
This Privacy Policy explains how Roomcall, the trading name of the sole proprietor identified in our Legal Notice ("we", "us", "our"), processes personal information in connection with the Roomcall service and website. It is issued in accordance with the Protection of Personal Information Act 4 of 2013 ("POPIA"). Roomcall is offered to practices in South Africa.
1. Responsible party and Information Officer
- Roomcall operates Roomcall, an online appointment book for medical practices. Our registered details are set out in our Legal Notice.
- Our Information Officer is our owner, who may be contacted through our contact page or at [physical address to be added]. Our full contact details are set out in our PAIA Manual.
2. Definitions
- In this policy, "personal information", "processing", "responsible party", "operator", "data subject" and "special personal information" have the meanings given to them in POPIA.
- "Practice" means a medical, dental or allied health practice that holds a Roomcall account. "Practice Data" means information entered into Roomcall by or on behalf of a Practice, or by patients through a Practice's booking page.
3. Our role
- Responsible party. We are the responsible party for personal information about Practices, their account users, and visitors to our website.
- Operator. For Practice Data, including patient information, the Practice is the responsible party and we are its operator. We process Practice Data only on the Practice's instructions and to provide Roomcall to it, under our Data Processing Agreement.
4. Information about practices and visitors
- We process the following personal information about Practices and their account users:
- Account details: the practice name, the sign-in email address, time zone, clinic hours, appointment types and booking page settings;
- Credentials: the account password, stored only as a one-way hash that cannot be converted back into the password;
- Sign-in records: the time of the most recent sign-in, and a hashed token that keeps each device signed in for up to 90 days;
- Acceptance records: the date on which the Terms of Service were accepted and the version accepted;
- Billing records: the plan selected and the payments made. Payment card details are processed by Paddle, our online reseller, and are not received by us; and
- Correspondence: emails exchanged with us.
- When any person uses our website or the service, the internet protocol (IP) address of their device is held temporarily in our server's memory to prevent repeated incorrect passwords, mass sign-ups, misuse of booking pages and excessive messages through our contact page. It is not stored in our database. Our hosting provider keeps short-lived technical logs, which may include IP addresses, for security and fault-finding.
- When any person sends a message through our contact page, we process the name, email address, practice name (if given) and message that they enter, in order to reply. The message is stored in our database and read only by us.
5. Information about patients
- For each appointment, a Practice may record the patient's name, telephone number, reason for the visit, appointment type, date and time, and attendance status. Practice staff may also exchange short messages about the day's appointments. These are deleted automatically when that day ends.
- A patient who books through a Practice's booking page provides their name and telephone number, which are added to that Practice's appointment book. The booking page never shows other patients' details.
- A reason for a visit may constitute information about a person's health, which is special personal information under POPIA. The service is designed to hold only the information that an appointment book requires, and Practices undertake not to record clinical notes or health records in it.
- Patients. The Practice with which you booked is responsible for your personal information. Requests to access, correct or delete it, or questions about how it is used, should be directed to that Practice. If you contact us instead, we will refer your request to the Practice.
6. Purposes and lawful grounds
- We process personal information for which we are the responsible party for the following purposes and on the following grounds:
Purpose Lawful ground Providing the service to a Practice, including account administration and billing Performance of a contract (POPIA s11(1)(b)) Security, prevention of misuse, and fault-finding Legitimate interests, and our obligation to secure personal information (POPIA s11(1)(f) and s19) Communications about the account, trial, payments and changes to our terms Performance of a contract (POPIA s11(1)(b)) Replying to messages sent through our contact page Legitimate interests in answering enquiries, or steps taken at the sender's request before a contract (POPIA s11(1)(b) and (f)) Compliance with tax, accounting and other legal obligations Legal obligation (POPIA s11(1)(c)) - We process Practice Data solely to provide the service to the Practice concerned.
- We do not sell personal information, use it for advertising, or create profiles of individuals. We do not use Practice Data for any purpose of our own, including analytics or the training of artificial intelligence models.
8. Cross-border transfers
- The Roomcall application servers and its primary database, including the database's backups, are hosted in Johannesburg, South Africa.
- Some supporting processing takes place outside South Africa: our hosting providers' technical logs and support functions, our email, which Microsoft stores outside South Africa, and the processing of subscriptions by Paddle described in clause 8.4, and the sending of automated account emails by Resend described in clause 8.5. Our operators are international companies and may also access information from outside South Africa to provide support or meet legal obligations.
- We permit personal information to be transferred outside South Africa only where section 72 of POPIA allows it, in particular where the recipient is bound by a law, binding corporate rules or a binding agreement that provides an adequate level of protection substantially similar to POPIA, or, for email correspondence, where the transfer is necessary to correspond with you about the service or at your request.
- When a Practice subscribes, its account email address and a reference to the Practice are sent to Paddle, our online reseller, which is based in the United Kingdom. The United Kingdom has data protection law substantially similar to POPIA. No patient information is sent to Paddle.
- Automated account emails are sent from Resend's data centre in Ireland, in the European Union, whose data protection law is substantially similar to POPIA. Resend is based in the United States and may access these emails from there to provide its service. Each email contains an Account's email address and, for a password reset, a link that expires after 30 minutes; no patient information is sent to Resend. These transfers take place under Resend's data processing terms, in accordance with section 72 of POPIA.
9. Retention
- Account details and Practice Data are retained while the Practice's account is open. Practices may delete appointments themselves at any time. Messages between reception and the practitioner are deleted automatically once the day they relate to has ended in the Practice's time zone, or earlier when either side clears them. Copies of deleted messages may remain in encrypted database backups until those backups are overwritten, within 30 days.
- When an account ends, whether by cancellation, termination or the end of a free trial without a paid plan, its data is retained for 90 days so that the Practice may return or request a copy. It is then permanently deleted. Backup copies are overwritten within a further 30 days.
- Billing records are retained for five years, as required by South African tax law.
- Correspondence, including messages sent through our contact page, is retained for up to two years after it is answered or, for a Practice, after its account ends, whichever is later.
- Resend's log of automated account emails is deleted after 30 days.
10. Security safeguards
- In accordance with section 19 of POPIA, we maintain appropriate and reasonable technical and organisational measures to protect personal information, including:
- encryption of all connections to the service;
- storage of passwords and sign-in tokens only as one-way hashes;
- temporary lock-out of sign-in after repeated incorrect passwords;
- separation of each Practice's data at database level, so that no Practice can access another Practice's data;
- booking pages that show available times only, and never other patients' details; and
- restriction of access to production systems to personnel who require it.
- No system is completely secure. If a security compromise affects personal information for which we are the responsible party, such as account details or contact messages, we will notify the affected persons and the Information Regulator as required by section 22 of POPIA. If it affects Practice Data, we will notify the Practice immediately, as its operator, and help it meet its own obligation to notify.
11. Rights of data subjects
- Subject to the applicable law, you have the right to:
- be informed whether we hold personal information about you, and to request access to it;
- request the correction, destruction or deletion of your personal information;
- object to the processing of your personal information, and request that its processing be restricted; and
- lodge a complaint with the Information Regulator.
- Requests should be sent to our Information Officer through our contact page, or by using the contact details in our PAIA Manual. We will respond within 30 days and may first need to verify your identity. Formal requests for access to records may also be made under the Promotion of Access to Information Act 2 of 2000, as described in our PAIA Manual.
- Patients should first direct requests to the relevant Practice, as described in clause 5.4.
- Complaints may be lodged with the Information Regulator (South Africa) at inforegulator.org.za.
13. Direct marketing and automated decisions
- We do not send unsolicited electronic direct marketing. Emails to Practices relate to their account and the service. We never contact patients.
- We do not make decisions about any person based solely on automated processing.
14. Children
- Accounts may be opened only by adults acting for a Practice. A Practice may record appointments for children; that information is Practice Data under the Practice's responsibility. Online bookings for a child should be made by a parent or guardian.
15. Changes to this policy
- We may amend this policy. The effective date and version at the top of this page identify the current version. We will notify Practices by email before any material amendment takes effect.