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HILBI IQ · DATA PROCESSING

Where your data goes, in writing

  • Processed in the EU
  • No model training
  • Clinician signs first

Patient data stays in the EU and never trains a foundation model. The processing location, the legal basis, the retention clock and the audit trail are contract terms, not promises.

Who is responsible for the output
Platform security
Where your data goes, in writing

EU and India

processing location per market

Signature gate

nothing is filed without a clinician

How IQ handles patient data

Four properties, each checkable against a document rather than a promise.

  1. Processing stays in the EU

    The European Union for Slovakia and Czechia. India for the Indian market, under the DPDP Act 2023. A contract term, not a preference.

  2. It never trains a foundation model

    Written into the processing agreement. It is the first thing to check with any vendor, including us.

  3. The clinician signs first

    IQ drafts and suggests codes. Nothing enters the record without a signature: § 21 in Slovakia, § 12 in Czechia.

  4. Every action is logged and reversible

    What was generated, what changed, who signed and when. Immutable, and yours to export.

What a DPO needs before shortlisting IQ

In the order a review asks it. Every row answered.

Processing locationIn force
European Union for the Slovak and Czech markets; India for the Indian market. Stated per market, never as one global claim.
Model trainingIn force
Patient data is not used to train foundation models. Contractual, not a setting.
Legal basisIn force
Art. 9(2)(h) GDPR for health data in the provision of care, with Hilbi acting as processor under Art. 28.
Transparency toward the patientIn force
AI Act (EU) 2024/1689 Art. 50(4): machine-generated clinical text is disclosed as such and carries the clinician who signed it.
Human oversightIn force
The clinician reviews and signs. IQ does not diagnose and it does not decide; the intended purpose is stated so the MDCG 2019-11 assessment is reproducible.
Audit trailIn force
Immutable and exportable: what was generated, what was edited, who signed, when.
Security of processingIn progress
Art. 32 GDPR controls, managed under an information-security management system currently in ISO/IEC 27001 recertification at group level.
RetentionIn force
Prompts and drafts for 30 days, signed output under national retention law, audit records for 10 years. The deletion evidence is yours.
Sub-processorsIn force
Fourteen sub-processors with the purpose and the processing location of each, listed per market.
ExitIn force
Monthly term. Your clinical record stays in your system of record; patient-held data exports as an HL7 FHIR R4 bundle.

The instruments this page answers to

Each row is the rule a reviewer will check this page against.

EUEuropean Union
  • GDPR (EU) 2016/679Art. 9(2)(h) legal basis, Art. 28 processing agreement, Art. 32 security of processing, Art. 33 and 34 breach notification.
  • AI Act (EU) 2024/1689Art. 50(4) transparency for machine-generated content; Art. 6(1) classification, addressed on the responsibility page.
  • EU MDR 2017/745 with MDCG 2019-11The intended-purpose statement that keeps the classification assessment reproducible.
SKSlovakia
  • Act 576/2004 Coll. §21The clinician's signature before a record entry is final.
CZCzechia
  • Decree 98/2012 §12 and §7(1)Record content and the immutability of the trail.
INIndia
  • DPDP Act 2023Consent, notice and the duty to notify.
ISOStandards
  • ISO/IEC 27001 with ISO 27799Information-security management applied to health data. Recertification in progress at group level.

What clinicians and their DPOs ask

  • Not for the Slovak and Czech markets: the processing location is the European Union and it is a contractual term. The Indian market is processed in India under the DPDP Act 2023.