Health Data and Medical Documents
This health data notice covers the most sensitive thing we handle: your medical summary and uploaded reports. It explains the legal basis, who can open a document, how access is logged, where files are stored, and how to have everything deleted.
- Written by
- Organ Transplant Experts
- Medically reviewed by
- Organ Transplant Experts
- Reviewed
- Updated
In short
When you describe your condition or upload a medical report, you are giving us the most sensitive category of personal information the law recognises. We handle it only with your explicit consent, only to get your case reviewed, and only for as long as that takes. Documents are stored privately, are never publicly reachable, are opened through a short-lived link by a signed-in coordinator, and every single access is logged. Nothing is sent to a hospital until you agree to that named hospital, and you can have everything deleted at any time without giving a reason.
Why this needs its own page
Our privacy policy covers everything we handle. This page covers one part of it in more detail — medical records privacy, and what happens when you attach a file — because it is the part that matters most and the part people are right to think twice about.
When you fill in the enquiry form, most of what you enter is ordinary personal information: a name, an email address, a phone number. But the box where you describe your condition, and any report you attach, are something else. Under European law they are special category data, and under several other frameworks they are sensitive personal information. Both terms mean the same thing in practice: a higher bar to handle them at all, and more that we owe you.
There is a second reason, less legal and more practical. Our readers are in countries where a diagnosis can affect employment, insurance, immigration status, a marriage negotiation or a family's standing. A leaked kidney failure diagnosis is not the same kind of problem everywhere, and we would rather design for the worst case than the average one.
So this page tells you exactly what happens to a medical document from the moment you attach it: what we do with it, who can open it, where it physically sits, what protections exist, what protections do not yet exist, and how to make it all go away.
- Your medical summary and reports are special category data under European law.
- Other frameworks call the same thing sensitive personal information.
- Both mean a higher bar to handle them and more that we owe you.
- A diagnosis can affect employment, insurance, immigration or family standing.
- We design for the worst case rather than the average one.
- This page tracks a document from attachment to deletion.
The legal basis: explicit consent, and what that gives you
We handle your medical information on one basis only: your explicit consent under Article 9(2)(a) of the GDPR. Not a contract, not our legitimate interests, not a public health exemption. Explicit consent.
Explicit is a higher standard than ordinary consent. It has to be a clear affirmative act, specific to this purpose, given freely, and it must be as easy to withdraw as it was to give. That is why the enquiry form asks you to tick a separate box for medical information rather than bundling it into one general agreement, and why the exact sentence you agreed to is stored alongside your record. If we later reword that sentence, your record still shows what you actually read.
Building on consent rather than on something more convenient has a cost to us and a benefit to you, and the benefit is the point.
You can withdraw at any time, and we stop. Not "we will consider your request", not "unless we have a legitimate interest in continuing" — we stop.
You never have to justify a deletion request. Under some other legal bases, a controller can weigh its interests against yours. With consent, removing the consent removes the lawfulness, so there is nothing to weigh.
And refusing costs you nothing you are entitled to. You can send an enquiry with no medical details at all, and we will tell you everything we can without them — which is more than most people expect.
- One basis only: explicit consent under Article 9(2)(a).
- Explicit means a clear, specific, freely given affirmative act.
- A separate tick for medical information, never bundled into a general agreement.
- The exact sentence you agreed to is stored with your record.
- Withdraw at any time and we stop; there is nothing to weigh against you.
- You never have to justify a deletion request.
- You can enquire with no medical details, and still get a useful answer.
What happens to a document you upload
| Step | What happens |
|---|---|
| You attach a file | It is sent to us over an encrypted connection |
| We store it | In private storage, in a separate area from anything public |
| We name it | With a generated key, never with your file name — names leak information and collide |
| We record it | Original name, type, size and a checksum, so a duplicate re-upload is recognisable |
| We mark it | As unscanned, because automated malware scanning is not yet in place |
| A coordinator opens it | Through a short-lived signed link that expires, never a permanent address |
| We log the access | Who opened it, and when — every time, without exception |
| You agree to a centre | Only then is anything transmitted, and only to the centre you named |
| You ask for deletion | The file is removed from storage, not merely unlinked from your record |
Who can open your documents, and how we know
Access to an uploaded document requires being signed in as a coordinator or an administrator, and it produces a log entry every time. That log records who opened the document and when, and it is not something a member of staff can switch off for a particular file.
This is worth explaining because it is a different control from the one most organisations describe. Restricting who may access something is a promise about intentions. Logging every access is a record of what happened, which can be checked afterwards by somebody who was not there. If you ever ask us who has opened your reports, we can answer the question rather than describe our policy.
Documents are not reachable at a public address. There is no URL that could be guessed, shared or indexed by a search engine. The only route to a file is a link generated on demand for a signed-in member of staff, which stops working shortly afterwards.
Public content and private case data are kept apart at the database level rather than by careful coding. That distinction matters: a mistake in application code cannot expose a case file through a public page, because the public side has no route to that data at all.
Outside our team, nobody sees a document until you agree to a specific named transplant centre. We do not circulate a case to several hospitals to see who bites, and we do not send anything to a centre you have not been told about.
- Opening a document requires a signed-in coordinator or administrator.
- Every access is logged with who and when, and cannot be switched off.
- Ask us who has opened your reports and we can answer, not just describe a policy.
- No public address exists for a document; nothing is guessable or indexable.
- Links are generated on demand and expire shortly afterwards.
- Public and private data are separated at the database level.
- Nothing goes to a hospital until you agree to that named hospital.
One control we do not yet have
Automated malware scanning of uploaded files is not in place. Our system records every uploaded document as unscanned rather than marking it clean, because a file described as safe by nobody is worse than a file honestly marked unchecked. We are telling you this rather than letting a security page imply a control that does not exist. In practice it means uploaded files are handled with the caution that assumption requires, and it is on our list to fix.
Uploading medical reports: sending less, and sending it safely
You are in control of how much you send, and more is not always better. A few practical things worth knowing before you attach anything.
You can enquire with nothing. A question with no medical details at all still gets a useful answer: which centres run the programme, what the pathway involves, whether travel is even lawful for your situation, what a case review would need. Many people should start there.
Send what answers the question, not everything you have. A transplant team assessing candidacy wants recent imaging, recent bloods, and the letters that explain your diagnosis and current treatment. It does not need fifteen years of records, and sending them makes the review slower rather than more thorough.
Remove what is not needed. If a document carries an identity number, an insurance number or an address that has nothing to do with the clinical question, you are entitled to obscure it before sending. Nobody reviewing your case needs it.
Be careful about the device. If you are using a shared or family computer, the browser may keep what you typed in form fields and may keep a copy of a file you attached in a downloads folder. That is the browser rather than us, but it is where information most often leaks in practice.
And if a document belongs to somebody else — a potential donor's reports or identity papers — you need their agreement first. It is their information, and it is not yours to give.
- You can enquire with no medical details and still get a useful answer.
- Send what answers the question: recent imaging, recent bloods, the key letters.
- Fifteen years of records makes a review slower, not more thorough.
- You may obscure identity, insurance or address details that are not clinically relevant.
- A shared device is where information most often leaks; check the browser afterwards.
- A potential donor's documents need that person's agreement, not yours.
Deletion, and what we cannot delete
Ask us to delete your information and we will, without asking why. That covers the enquiry, the notes on it, and the uploaded documents, which are removed from storage rather than hidden from a screen.
There are two honest limits, and we would rather state them than let you discover them.
If your case has already been sent to a transplant centre with your agreement, that hospital holds its own copy under its own national law and its own retention rules. We cannot reach into their systems. What we will do is tell you clearly that it happened, which centre has it, and how to make a request to them directly — including the contact details, so it is a five-minute task rather than a research project.
And where a specific law requires us to keep a record, we keep that record for the period the law specifies and no longer. In practice this affects very little, and never the clinical documents.
We will also delete on our own initiative. An enquiry that goes nowhere does not need to sit on a server indefinitely, and the reports attached to it are the most sensitive thing we hold. We would rather hold less.
To make a request, write to the privacy address at the foot of this website and quote your enquiry reference if you have one. We answer within a month, and usually far sooner than that for a deletion, because there is nothing to deliberate about.
- Ask for deletion and we do it, without asking why.
- Documents are removed from storage, not merely unlinked.
- A hospital that already has your case holds its own copy under its own law.
- We tell you which centre, and give you the contact details to ask them.
- A legal retention requirement is kept for its period and no longer.
- We also delete on our own initiative; we would rather hold less.
- Quote your enquiry reference; deletions are usually done well inside a month.
Common questions
Is my medical information covered by HIPAA?
No, and that is a statement about which framework applies rather than about how well you are protected. HIPAA governs healthcare providers, health plans and clearing houses in the United States, and those who process data on their behalf. We are none of those: we do not provide care and we do not act for a provider. What protects your information here is our own commitment, the GDPR standard we apply to everyone regardless of where they live, and the state privacy laws that cover sensitive personal information. If you are in Washington State, we also honour requests under the My Health My Data Act.
Can I send an enquiry without uploading anything?
Yes, and for a first contact it is often the sensible choice. We can tell you which centres run the programme you are asking about, what the pathway involves, whether travelling for it is lawful in your situation, and what a case review would need — none of which requires a single document. Reports only become necessary when you want a transplant team to give an actual opinion on your case, because nobody can assess a patient from a paragraph.
Who exactly reads what I write in the medical summary box?
The coordinators handling your enquiry, and administrators who maintain the platform. That is a small number of people, all signed in to an account that identifies them. If your case is passed to a transplant centre with your agreement, their clinical team reads it too. It is not read by anyone else, it is not used for marketing, and it is never shared with an advertiser or a data broker — we have no such relationships at all.
Where are my documents physically stored?
On servers in the United States, which is where our hosting provider runs the infrastructure this platform is deployed on. For readers in the European Economic Area and the United Kingdom that is a restricted transfer under Chapter V of the GDPR, covered by Standard Contractual Clauses and the UK Addendum. Our privacy policy explains this in full, including the honest part: contractual protections reduce the risk of another country's authorities demanding access, but they do not abolish it.
What if I upload something by mistake?
Tell us and we will delete it. There is no process to go through and no form to fill in — say which file and we remove it from storage. If it has already been sent to a transplant centre, we will tell you and give you their details so you can ask them as well, but if the mistake is caught before that step then it simply stops existing on our side.
Do you use my medical information to train an AI system?
No. Your medical summary and your documents are used to get your case reviewed and for nothing else. They are not used to train or tune any model, they are not included in any dataset, and they are not shared with any company that does that. Our legal basis is your explicit consent for a stated purpose, and using the data for a different purpose would not be covered by it.
Sources
The frameworks this notice applies. Linked so you can check what they require against what we say we do.