Privacy Policy for the ‘Onboard’ App for iOS

Last updated: 17 March 2026

This Privacy Policy explains how Onboard ("we", "us", "our") handles personal data when the Onboard application is used by dental practices and clinicians to manage patient onboarding, consultation capture, transcription, and related workflow tasks.

1. Who We Are

Onboard is a dental onboarding and consultation workflow application.

Company name: Resilient Digital Ltd

Registered address: 11 Oberon Close, Lincoln. LN1 1WE  

Contact email: Info@resilientdigi.com 

If you are a patient whose data is entered into Onboard by a dental practice, that dental practice will usually be the **data controller** for your patient and consultation data. In those circumstances, Onboard will usually act as a **data processor** providing software and related processing services to the practice.

If you are a clinician, staff user, or business contact dealing directly with us, we may act as controller for your account, support, security, and business-administration data.

2. Scope of This Policy

This Privacy Policy applies to:

- clinicians and staff using the Onboard app;

- patients whose information is recorded in the app by a participating dental practice;

- limited business, technical, and support contacts interacting with us about the service.

3. Personal Data We Process

Depending on how the app is used, Onboard may process the following categories of personal data:

Patient identity and contact details

- first name and last name;

- preferred name;

- date of birth;

- NHS number, where entered;

- mobile number;

- email address;

- postal address;

- GP practice details;

- administrative notes.

Consultation and clinical information

- patient pseudonym used within the consultation workflow;

- consultation date and time;

- clinician comments;

- consultation transcript;

- structured clinical output;

- treatment-planning and costing information;

- follow-up and workflow status fields;

- dental and oral-health information;

- other health information discussed during the consultation.

Audio, image, and document data

- consultation audio recordings;

- consultation photos added by the user;

- exported PDFs, text outputs, and related consultation documents.

Technical and security data

- authentication token stored securely on device;

- backend request identifiers;

- service diagnostics such as file size, processing status, timestamps, and error information;

- limited server-side security and operational logs.

4. How Data Is Collected

We collect data in the following ways:

- when a clinician or staff member enters patient details into the app;

- when a consultation is recorded using the device microphone;

- when consultation photos are captured or added;

- when consultation data is submitted to the backend for transcription and structuring;

- when users configure practice branding, backend settings, or support-related settings;

- when the app generates outputs such as treatment plans, transcripts, and PDFs.

5. How We Use Personal Data

We use personal data to:

- create and manage patient onboarding records;

- record and document dental consultations;

- transcribe consultation audio;

- convert transcripts into structured clinical information;

- support clinician review, treatment planning, pricing, and workflow management;

- generate exportable consultation and treatment-plan documents;

- maintain service security, authentication, troubleshooting, and reliability;

- comply with legal, regulatory, and contractual obligations.

We do not use patient consultation data for advertising.

We do not sell personal data.

The ‘Onboard’ app does not keep any personal data for any longer than is necessary for the dental practice to complete the process of enrolling a new patient into their other systems or management processes.

No personal identifying information is stored in the ‘backend’ server that facilitates the ‘Onboard’ app workflow. The recording information is pseudonymised on the iOS application prior to transmission to the ‘backend’ server.

6. Legal Bases

Where a dental practice uses Onboard for patient care, the dental practice is usually responsible for identifying the lawful basis for processing under UK GDPR and, where relevant, the condition for processing special category data.

In a typical UK dental-care setting, the lawful basis is likely to relate to the provision and administration of healthcare services, and the special-category condition is likely to relate to health or social care or treatment. This should be confirmed by the relevant dental practice and its legal advisers.

Where we process data for our own business operations, security, support, and administration, we rely on lawful bases such as contract, legal obligation, and legitimate interests, as appropriate.

7. Special Category Data

Onboard may process **special category personal data**, including health data, consultation audio, clinical notes, oral-health findings, treatment discussions, and consultation images. Because this data is sensitive, we expect dental practices using the app to implement suitable confidentiality, consent, governance, and record-keeping procedures. The Company cannot be held responsible for the governance or procedures of the dental practices using the ‘Onboard’ app.

8. Sharing of Personal Data

We may share or make data available to:

- the dental practice, clinicians, and authorised staff using the app;

- service providers that support hosting, storage, authentication, speech processing, and structured processing;

- professional advisers, auditors, regulators, law enforcement, or courts where required.

Based on the current service configuration in this repository, consultation processing may involve Google Cloud services, including hosted backend infrastructure, cloud storage used during processing, speech-to-text services, and AI-based structured extraction services.

We require service providers acting on our behalf to protect personal data appropriately and only process it for authorised purposes. More information on how Google manages your data, and ensures data privacy may be found: https://docs.cloud.google.com/vertex-ai/generative-ai/docs/vertex-ai-zero-data-retention

9. International Transfers

We aim to process data in appropriate jurisdictions and with appropriate safeguards. Based on the current repository configuration, the backend is configured for processing in `europe-west2` (UK region designation used in Google Cloud deployment settings). If personal data is transferred outside the UK, we will ensure appropriate safeguards are in place where required by law.

10. Storage and Security

The app stores some data locally on the user’s device, including patient records, consultation records, audio filenames, photos, transcripts, and generated outputs.

The app also stores the consultation authentication token in the device keychain or equivalent secure credential storage.

We use technical and organisational measures designed to protect personal data, including access controls, authentication, secure transport, environment-based configuration, and data minimisation in backend payloads. For example, the backend workflow uses a patient pseudonym rather than requiring full patient demographic details in the consultation-processing request.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Photo Library and Device Permissions

The app may request access to:

- **Microphone**: to record consultation audio;

- **Photos / Photo Library**: to allow consultation-photo handling and, on supported devices, optional export of consultation photos to a local album.

On iOS, if photo-album export is enabled by the user, consultation photos may be copied to an album titled **Onboard** in the device’s Photos library. This creates an additional device-level copy outside the app’s local storage.

12. Data Minimisation

We aim to minimise the personal data sent to backend processing services. Based on the current implementation, backend consultation-processing requests include:

- the consultation audio file;

- patient pseudonym;

- consultation timestamp;

- locale;

- limited technical diagnostics where applicable.

Direct demographic identifiers such as patient name, email, and address are not required in the backend processing request itself, although they may still appear in consultation audio or local exports depending on how the app is used.

13. Data Retention

We retain personal data only for as long as necessary for the purposes described in this policy, unless a longer retention period is required by law, regulation, professional standards, or contract.

Retention may vary depending on the role and context:

- **Local app data** may remain on the device until deleted by the practice or user;

- **Exported files** may remain wherever the user stores or shares them;

- **Operational logs and diagnostics** may be retained for limited security and troubleshooting periods;

- **Support and account records** may be retained for business, legal, and audit purposes.

Based on the current backend configuration in this repository, staged backend audio is configured for **immediate deletion after processing**. 

Each dental practice should define and document its own patient-record retention periods.

14. Automated Processing

The app uses automated processing to generate transcripts and structured clinical outputs from consultation content. These outputs are intended to support clinician workflows and documentation. They should be reviewed by an appropriately qualified human user and should not be relied on without professional verification.

The app is not intended to make solely automated decisions with legal or similarly significant effects on individuals without human review.

15. Your Rights

Depending on your role and applicable law, you may have rights to:

- be informed about how your data is used;

- request access to your personal data;

- request correction of inaccurate data;

- request deletion in some circumstances;

- request restriction of processing;

- object to certain processing;

- request portability where applicable;

- lodge a complaint with the UK Information Commissioner’s Office (ICO).

If you are a patient, requests relating to your clinical and consultation data should usually be directed first to your dental practice, as the likely controller of that data.

ICO website: [https://ico.org.uk](https://ico.org.uk)

16. Children

The app may be used in dental settings involving children or young people where this is clinically appropriate. In such cases, the relevant dental practice is responsible for ensuring the lawful and appropriate handling of the child’s personal data and any required parental responsibility, safeguarding, confidentiality, and consent processes.

17. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will publish the updated version and revise the “Last updated” date above.

18. Contact Us

If you have questions about this Privacy Policy or our data-handling practices, contact:

Info@resilientdigi.com 

If you are a patient and your query relates to dental records or consultation data, please also contact the relevant dental practice that collected your information.