Publication note: This policy is drafted for a Pakistan-focused telehealth service and intentionally does not describe the 2023 Personal Data Protection Bill as enacted law.
1. Purpose
This Privacy Policy explains how Dial In Doctor collects, uses, stores, shares, protects, and otherwise processes personal information when you use our website, patient portal, healthcare coordination, consultations, payments, documents, and related services.
Healthcare data can be highly sensitive. We apply heightened access and security controls to clinical and identity information.
2. Who this applies to
This policy may apply to:
- patients;
- parents/guardians acting for a patient;
- healthcare professionals;
- staff and contractors;
- prospective users;
- website visitors;
- institutional/customer contacts;
- partner contacts.
Separate workforce or business-to-business privacy terms may also apply.
3. Information we may collect
Identity and account data
- name;
- MR/patient reference;
- date of birth/age where needed;
- gender/sex information where clinically relevant;
- account/security metadata;
- patient-chosen PIN hash (not the plaintext PIN).
Contact data
- phone;
- email;
- address where required;
- emergency/guardian/contact relationship information where appropriate.
Clinical/health data
Depending on the service:
- symptoms and health concerns;
- medical history;
- consultation notes;
- diagnoses or clinical impressions;
- prescriptions;
- medication information;
- allergies;
- laboratory orders/results;
- referrals;
- certificates;
- follow-up data;
- documents supplied by the patient/provider.
Appointment and service data
- appointment references;
- provider assigned;
- consultation type;
- dates/times;
- status;
- coordination history.
Payment/financial metadata
- amount;
- currency;
- payment provider/method;
- provider transaction/tracker reference;
- payment status;
- processor fee where supplied;
- receipt information;
- refund/reconciliation status.
Where a hosted payment gateway collects card details, card-entry information is handled by that provider. Dial In Doctor should not collect or store full card credentials unless a separately approved payment design explicitly requires it.
Technical/security data
- IP/network information;
- browser/device information;
- session/cookie information;
- authentication events;
- security/audit logs;
- error/diagnostic information.
Communications
- support messages;
- emails;
- operational notices;
- consent/preferences;
- complaint/refund correspondence.
4. How we use information
We may process information to:
- create and secure accounts;
- identify the correct patient;
- arrange consultations;
- support healthcare professionals in delivering care;
- manage prescriptions/labs/certificates/follow-ups;
- coordinate healthcare services;
- process and reconcile payments;
- generate accurate receipts;
- prevent fraud and unauthorized access;
- support users;
- investigate incidents/complaints;
- maintain clinical/financial/legal records;
- improve reliability and usability;
- comply with legal/regulatory obligations;
- establish, exercise, or defend legal claims.
We will not use clinical data for unrelated advertising in a manner inconsistent with law, consent, or reasonable patient expectations.
5. Lawful/authorized basis
Depending on the context, processing may be necessary for:
- providing a service requested by you;
- healthcare delivery and coordination;
- your consent where required;
- legitimate security/operational purposes;
- legal/professional obligations;
- protection of vital interests in an appropriate emergency;
- financial, tax, accounting, and dispute records.
Where explicit consent is required by applicable law, we will seek it.
6. Sensitive health data
We apply heightened controls to health and clinical information.
Access should be limited to:
- the patient/authorized representative;
- treating/authorized healthcare professionals;
- authorized operational staff on a need-to-know basis;
- approved service providers/partners where necessary;
- persons/entities where disclosure is legally required.
7. Sharing
We may share only what is reasonably necessary with categories such as:
- healthcare professionals;
- laboratories;
- pharmacies;
- hospitals/referral providers;
- payment processors (including Safepay where enabled);
- hosting/infrastructure providers;
- email/communications providers;
- professional advisers/auditors;
- regulators, courts, law-enforcement, or public authorities where lawfully required;
- business/institutional customers where a valid contract and data role permits it.
We do not sell patient medical records to advertisers.
8. Service providers / processors
Service providers must be given only the access needed for their function and should be subject to appropriate confidentiality, security, and contractual restrictions.
Where Dial In Doctor processes data for an institutional customer, the applicable Data Processing Agreement may control the controller/processor relationship.
9. International / cross-border processing
Technology providers may process or store data outside the user's city or outside Pakistan depending on the approved hosting/service architecture.
Where cross-border processing occurs, Dial In Doctor will use contractual, security, and legal safeguards appropriate to the data and applicable requirements.
Before publication, the production subprocessor/hosting list should be verified against the actual deployed architecture.
10. Retention
We retain data only for as long as reasonably necessary for the relevant purpose and applicable legal/professional requirements.
General approach:
- clinical records: retained according to applicable professional/legal requirements and continuity-of-care needs;
- payment, invoice, tax and accounting records: retained for the required statutory period; Pakistan tax records commonly require six years of retention;
- security/audit records: retained for a proportionate security/investigation period;
- support/complaint records: retained while needed for resolution and defensibility;
- setup/reset tokens: short-lived; consumed/expired tokens are retained only as necessary for security/audit controls.
We may retain data longer where:
- a dispute/claim is pending;
- preservation is legally required;
- fraud/security investigation requires it;
- clinical/professional obligations require it.
11. Security
Controls include, as appropriate:
- encrypted HTTPS transport;
- hashed PINs;
- hashed single-use setup/reset tokens;
- role-based access;
- doctor/patient scoping;
- session/security-stamp controls;
- rate limiting;
- server-side IDOR protections;
- webhook signature verification;
- secret separation from source code;
- audit/event records;
- backups and recovery controls.
No system can be guaranteed completely secure. We maintain layered controls and respond to identified incidents.
12. Your choices and rights
Subject to applicable law and clinical/legal recordkeeping obligations, you may request:
- access to personal information;
- correction of inaccurate profile/contact information;
- information about processing;
- deletion of information that is not required to be retained;
- restriction/objection where legally available;
- withdrawal of consent for consent-based optional processing;
- marketing opt-out;
- account/security assistance.
A deletion request may not require deletion of a clinical, financial, legal, fraud, or audit record that must lawfully or reasonably be retained.
We may verify identity before fulfilling a request.
13. Children and dependants
Where services are provided for a minor/dependant, the responsible adult should have lawful authority to act for that person.
We may request information necessary to verify authority and protect the patient.
14. Cookies and sessions
The Platform may use essential cookies/session mechanisms required for:
- authentication;
- security;
- continuity;
- preferences.
If analytics/marketing cookies are later introduced, they should be documented and, where required, subject to consent/choice.
15. Automated systems
If automated tools support operations, they should not be represented as replacing the independent clinical judgment of a qualified healthcare professional unless specifically authorized and clinically governed.
Material automated decision-making affecting care or rights should be reviewed for transparency, safety, and applicable legal requirements before deployment.
16. Data incidents
If a security incident affects personal information, we will:
- investigate;
- contain and remediate;
- document relevant facts;
- notify affected parties and/or authorities when required by applicable law/contract;
- cooperate with relevant institutional customers where a DPA applies.
17. Changes to this Policy
We may update this Policy when services, vendors, regulations, or data practices change.
The published version should display its effective date.