1. Purpose & Scope
Wellinovate Ltd. ("Wellinovate," "we," "us," or "our") develops connected clinical hardware, interoperable electronic health records (EHR), and diagnostic intelligence platforms. This Privacy Policy governs the processing of personal health information (PHI) and clinical telemetry across our eight core platforms: welliRecord, welliID, WelliCare, WelliPharm, WelliDiagnostic, WelliPay, WellISight, and WelliMate.
We treat health data as a sacred trust. Our infrastructure is engineered from first principles to prioritize patient confidentiality, clinical integrity, and institutional data sovereignty.
Fundamental Principle: Wellinovate will never sell, monetize, or broker patient health data. Clinical records belong solely to patients and their authorized licensed care providers.
2. Information We Process
Depending on whether you are a patient, healthcare provider, clinical administrator, or partner institution, we may process:
- Patient Identity & Biometrics: Universal patient identifiers created via
welliID, encrypted biometric facial/iris feature vectors (stored as non-reversible algorithmic hashes, never raw images), national identity reference numbers, and demographic details. - Electronic Health Records (EHR): Clinical encounter notes, consultation summaries, vital signs, diagnostic laboratory values, medication prescription histories, allergy registers, and referral files managed through
welliRecord. - Connected Diagnostic Telemetry: Diagnostic device readings, ECG captures, ultrasound imaging streams, and point-of-care vital measurements gathered via
WelliDiagnosticand validated clinical hardware. - Provider Professional Credentials: Medical license numbers, specialty registrations, facility affiliations, and authenticated access tokens.
- Audit & System Telemetry: Immutable cryptographic timestamps recording every chart opening, amendment, export, and prescription sign-off.
3. Legal Basis & Regulatory Alignment
We operate under strict adherence to global and continental privacy regulations:
- Nigeria Data Protection Act (NDPA 2023) & NDPR: Compliance with statutory principles of lawful processing, privacy impact assessments, and data subject rights.
- UK & EU General Data Protection Regulation (GDPR): Article 9 compliance governing special category health data for clinical treatment, diagnosis, and healthcare management.
- HIPAA Security & Privacy Rules Alignment: Technical and administrative safeguards meeting or exceeding international healthcare security baselines.
4. Clinical Security & Encryption Standards
Our security architecture adheres to zero-trust defense-in-depth principles:
- Encryption in Transit: All data transmitted between clinical hardware, client applications, and cloud/edge infrastructure uses TLS 1.3 with Perfect Forward Secrecy.
- Encryption at Rest: All database volumes, object stores, and diagnostic cache layers are encrypted with AES-256 with keys managed through hardware security modules (HSM).
- Field-Level Encryption (FLE): Sensitive identifiers and clinical diagnostic markers are encrypted individually at the application layer prior to database insertion.
- Air-Gapped Local Clinical Continuity: In facilities experiencing grid or internet interruption, local nodes maintain cryptographic synchronization queues that verify integrity upon reconnect.
- Immutable Audit Logging: Every record view, export, modification, or transmission is recorded in a tamper-evident audit ledger compliant with clinical governance audits.
5. Interoperability & Authorized Data Sharing
We share data exclusively within authorized clinical care pathways:
- Direct Patient Care: Transfer of medical summaries between referring hospitals, specialist clinics, diagnostic laboratories, and pharmacy networks with explicit clinical consent.
- Open Interoperability Standards: System-to-system integrations are executed using standard HL7 FHIR (Fast Healthcare Interoperability Resources) REST APIs with scoped OAuth 2.0 authorizations.
- Statutory Health Reporting: In strictly bounded instances mandated by public health law (e.g., epidemic reporting of notifiable infectious diseases), anonymized statistical notifications are transmitted to accredited public health authorities.
6. Patient & Provider Rights
Under applicable privacy law, individuals whose health data is managed within Wellinovate systems enjoy clear rights:
- Right of Access: Patients may review their complete clinical history, lab results, and consultation notes via the patient-facing portal.
- Right to Rectification: Correction of erroneous personal details or addenda to medical records as governed by medical recordkeeping standards.
- Right to Data Portability: Complete export of your personal medical history in standard FHIR JSON or human-readable formats.
- Access Revocation: Revocation of secondary access privileges granted to family members, insurance providers, or research programs.
7. Data Retention & Regional Sovereignty
Clinical data retention periods are governed by statutory national medical recordkeeping mandates (typically 7 to 10 years following the last clinical encounter, or until the age of majority for pediatric records). Upon expiration of statutory periods, records are purged according to DoD 5220.22-M sanitization standards.
We respect national data sovereignty requirements by hosting regional health data within in-country cloud data centers or approved sovereign infrastructure.
8. Data Protection Officer (DPO) Contact
If you have questions regarding this Privacy Policy, wish to exercise your data subject rights, or need to lodge a clinical governance inquiry, contact our dedicated data protection office:
- Data Protection Officer: dpo@wellinovate.com
- Privacy Inquiries: privacy@wellinovate.com
- Headquarters: Wellinovate Ltd., Lagos · London · Global Remote