Terms and data processing agreement

The clinic is the data controller. Anotera is the data processor.

The clinic owns the clinical record and decides what it says, who may see it, and when it is deleted. Anotera runs the server, the software and the backups, and does nothing with the data other than what the clinic asks for through the system.

• Anotera cannot read the clinical record. Notes, client cards and messages are encrypted with a key derived from the clinician’s own. Anotera does not hold the key.
• Anotera can see what is not encrypted: the name of the clinic, telephone number, address, which psychologists exist, and how much space the clinic uses. Not client names, not appointment times, not content.
• The data is held in the EU, on a server at Hetzner in Germany or Finland. Backups are held in the same place, encrypted.
• Sub-processors: Hetzner (server), GatewayAPI (SMS). Changes are notified a month in advance.

The things only the clinic can do

• Look after the key. It is shown once. A lost key is a lost clinical record; Anotera cannot reset it.
• Be a clinic. The system is for authorised psychologists, psychotherapists and doctors under a duty of confidentiality. Anotera closes clinics that are not.
• Keep records as the law requires. Anotera is a tool; the duty is the clinician’s. The system helps with retention periods and export, but the decisions are the clinic’s.
• Tell its clients that the clinical record is kept electronically with a data processor, as the GDPR requires.

You can always leave

The clinic can at any time export everything: clinical record, calendar, clients, messages, in an open format, and close the account. After closure the data is deleted from the server after 30 days and from backups after 90. Anotera can close a clinic on a month’s notice, or at once, if it is used for something that is not clinical work. In both cases the data can be taken out first.

Questions: kontakt@anoteraclinic.com.