Privacy Policy

About This Policy

This Privacy Policy explains how RefNet Pro (“RefNet Pro”, “we”, “us”, “our”) collects, uses, discloses, stores, and protects personal information through the RefNet Pro referral management platform (“the Platform”).

RefNet Pro is designed for Australian medical specialist practices to manage incoming referrals from referring doctors. We are committed to handling personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

This policy applies to all users of the Platform, including medical practitioners, practice staff, and administrators.

1. What Information We Collect

RefNet Pro collects only the minimum information necessary to operate the referral management service. We collect personal information in the following categories.

1.1 User Account Information

When you create an account on RefNet Pro, we collect:

• Your name
• Your email address
• A password (which is hashed before storage — we never store your password in plain text)

1.2 Organisation and Practice Information

During onboarding, you provide:

• Your practice or clinic name
• Notification preferences (which event types trigger alerts, and via which channels)

1.3 Referring Doctor Contact Details

We collect and store the professional contact details of referring doctors associated with your referrals:

• Name, title, and qualifications
• Practice or clinic name(s) and associated addresses
• Professional specialty (up to 4 per contact)
• Phone, mobile, and fax numbers
• Professional email address
• Practice address (street, city, state, postcode)

1.4 Audit and Security Logs

We maintain security and compliance logs including authentication events, administrative actions, document processing records, and email processing metadata. Authentication logs are automatically deleted after 90 days.

1.5 Chat Conversations

If you use the AI assistant, your conversation history is retained in your account.

2. What Information We Do NOT Collect

RefNet Pro is built on a privacy-by-design principle. The following categories of information are not extracted, stored, or searchable within the Platform:

• Patient names, dates of birth, or contact details
• Medical Record Numbers (MRNs) or hospital identifiers
• Medicare numbers, insurance numbers, or health fund numbers
• Diagnoses, clinical notes, or pathology results
• Treatment plans, prescriptions, or medication lists
• Medical histories or surgical records
• Imaging reports or results
• Any government-issued identifiers (passport, driver licence, etc.)

This exclusion is enforced by design at multiple layers of the system.

3. How We Collect Information

3.1 Directly From You

We collect your account information when you register for the Platform. You may also manually add or edit referring doctor contact details, notes, and referral records.

3.2 From Inbound Referral Emails

We collect referring doctor contact details from referral correspondence you forward to the Platform.

3.3 Source Document Handling

Source documents (referral emails and attachments) are held only for the time needed to extract the referring doctor's details — typically seconds — and are then permanently deleted. We do not retain the content of referral letters or attachments.

3.4 From Bulk Imports

You may upload files containing existing contact data. These files are deleted from storage after processing.

4. How We Use Your Information

We use the information we collect for the following purposes:

• Referral management: To receive, classify, and track referrals on behalf of your practice.
• Contact management: To maintain a directory of referring doctors and their contact details for your practice.
• Search and analytics: To provide search, reporting, and insights on your referral data.
• Authentication and security: To verify your identity, manage your sessions, and protect your account.
• AI assistant: To provide a chat assistant for querying your referral data.
• Notifications: To send you in-app and email alerts about referral activity, system events, and items requiring review.
• Audit and compliance: To maintain records of document processing and system access for security monitoring.
• Service improvement: To monitor system performance and resolve technical issues.

We do not use your information for direct marketing. We do not sell, rent, or trade personal information to third parties. We do not use your data to train AI models (see Section 5.3).

5. AI Processing

RefNet Pro uses artificial intelligence to assist with several functions. We believe it is important to be transparent about how AI is used in the Platform.

5.1 How AI Is Used

We use AI to process referral documents, classify emails, support search, and provide a chat assistant. All AI processing occurs within Australia (AWS Sydney region). The AI service does not retain your data after processing and does not use it for model training.

5.2 AI Infrastructure and Data Sovereignty

All AI processing occurs within the AWS ap-southeast-2 (Sydney) region. Your data is processed entirely within Australian infrastructure and is not sent to overseas AI providers.

5.3 No Training on Your Data

The AI service does not use your data to train or improve AI models. Your Data is processed on a per-request basis for inference only. No input or output data is retained by the AI service after processing is complete.

6. Data Storage, Security, and Sovereignty

6.1 Where Data Is Hosted

All infrastructure components — including application hosting, database, file storage, AI processing, email handling, and background processing — are deployed in the AWS ap-southeast-2 (Sydney) region.

All platform data is stored and processed within Australia. The only exception is payment processing: if you subscribe to a paid plan, billing is handled by Stripe, a US-based payment processor (PCI DSS Level 1 compliant). Only your organisation's billing identifier is shared with Stripe — no health data, referral data, or referring doctor information is transferred.

Your Data remains subject to Australian law — specifically the Privacy Act 1988 (Cth) and the Australian Privacy Principles — at all times.

6.2 How Data Is Secured

• Data at rest: All stored data is encrypted at rest.
• Data in transit: All communications are encrypted in transit.
• Passwords: User passwords are hashed before storage. We cannot view or retrieve your password.
• Access controls: All routes require authentication, data is isolated between organisations, and role-based access control governs administrative functions.

6.3 Source Document Deletion

Source documents are deleted immediately after processing, typically within seconds. We do not retain referral letter content or attachments.

6.4 Data Retention

6.5 Data Deletion on Account Closure

When your account is closed, Your Data is permanently deleted from our systems. We recommend downloading your data from the Settings page before closing your account. Audit logs and compliance records may be retained in anonymised form as required by law.

6.6 Sub-Processors

Our primary infrastructure provider is Amazon Web Services (AWS). The AWS Asia Pacific (Sydney) Region maintains certifications including:

• ISO 27001 (Information Security Management)
• SOC 2 Type II (Security, Availability, Confidentiality)
• IRAP (Information Security Registered Assessors Program) at the PROTECTED level

7. Disclosure of Information

We may disclose personal information in the following limited circumstances:

• Within your organisation: Other authorised users within your practice or organisation can access shared referral and contact data through the Platform. Data is logically isolated between organisations — one practice cannot access another practice's data.
• Infrastructure providers: We use AWS to host the Platform and process data. AWS operates under its own privacy and security obligations, including encryption of data at rest and in transit. All AWS services used by RefNet Pro are located in the ap-southeast-2 (Sydney) region.
• Payment processing: If you subscribe to a paid plan, billing is handled by Stripe, a US-based payment processor (PCI DSS Level 1 compliant). This involves a cross-border transfer of your organisation's billing identifier to the United States. We do not store your full credit card number or payment credentials — these are handled directly by Stripe. No health data, referral data, or referring doctor information is shared with Stripe.
• Legal requirements: We may disclose information where required or authorised by Australian law, including in response to a court order, subpoena, or a lawful request from a regulatory authority.
• Serious threat: We may disclose information where we reasonably believe it is necessary to prevent or lessen a serious threat to the life, health, or safety of any individual, or to public health or safety, in accordance with APP 6.2(c).

8. Accessing and Correcting Your Information

Under APP 12 and APP 13, you have the right to:

• Access the personal information we hold about you.
• Request correction of any information that is inaccurate, out of date, incomplete, irrelevant, or misleading.

To request access to or correction of your information, contact us using the details in Section 12. We will respond to your request within 30 days. There is no charge for making a request or for corrections. We may charge a reasonable fee for providing access if the request requires substantial effort to fulfil.

If we refuse a request for access or correction, we will provide written reasons and inform you of the available complaint mechanisms.

You can update your own account details (name, email, password) directly through the Platform's settings at any time. Referring doctor contact details and referral data can be edited through the Platform interface by authorised users within your organisation.

9. Notifiable Data Breaches

In the event of an eligible data breach, we will comply with our obligations under the Notifiable Data Breaches (NDB) scheme (Part IIIC of the Privacy Act 1988 (Cth)). This includes:

• Conducting an assessment of any suspected breach within 30 days.
• Notifying the Office of the Australian Information Commissioner (OAIC) and affected individuals if the breach is likely to result in serious harm.
• Taking reasonable steps to contain the breach and mitigate potential harm.

We maintain a Data Breach Response Plan that outlines our incident assessment, containment, notification, and remediation procedures.

10. Cookies and Analytics

The Platform uses essential cookies for authentication and session management. We do not use third-party tracking cookies, advertising cookies, or cross-site analytics tools.

11. Complaints

11.1 How to Complain

Contact our Privacy Officer using the details in Section 12. Please provide:

• Your name and contact details
• A description of the issue
• The outcome you are seeking

11.2 Our Process

We will:

1. Acknowledge your complaint within 5 business days.
2. Investigate the matter and keep you informed of progress.
3. Provide a written response within 30 days, including any actions we propose to take.

12. Contact Us

If you have questions about this Privacy Policy, wish to make an access or correction request, or want to lodge a complaint, please contact:

Privacy Officer
RefNet Pro
Email: privacy@refnet.pro

13. Definitions