Privacy Impact Assessment (PIA)
Individual Users — Health Compass
Individual User Privacy Document. This PIA covers all users who access Health Compass directly as individuals — via qihub-he.com — without affiliation to an NZCAP group programme. Your data belongs to you alone.
Executive Summary
This Privacy Impact Assessment evaluates the flow of health information through the Health Compass application for individual users. Our "Privacy-by-Design" approach ensures that your personal health data — including wellness logs, mood tracking, assessments, and diary entries — is accessible only to you and those you explicitly choose to share with.
Unlike group programmes, individual accounts have no host organisation layer. There is no school, employer, or organisation that has any access to your data in any form. You are the sole data subject and the sole controller of your personal health sanctuary.
Definition — "System Administrator"
In this document, "system administrator" refers to app-level admin accounts within Health Compass (users assigned role: admin in the application). These accounts are restricted by Row-Level Security (RLS) rules enforced at the database query layer — they cannot access other users' health records through the application interface.
Separately, BASE44 (the Data Processor) holds infrastructure-level access to the underlying database as part of its hosting obligations. BASE44 operates under a Data Processing Agreement and is bound by its own privacy and security commitments as a processor under NZ Privacy Act 2020. The Data Controller (QiHub-Health Enterprise Ltd.) holds account-owner access to the BASE44 platform as required to operate and maintain the service.
Data Flow & Risk Mitigation
Compliance with HIPC 2020 Rules
Rule
Implementation Strategy
Rule 1: Purpose
Data collection is limited to personal wellness tracking and health programme participation. No data is sold, shared with advertisers, or used for any purpose beyond the user's own health journey.
Rule 3: Openness
Users are informed of all data practices at signup, within the onboarding flow, and via this FAQ. Data processing is fully transparent with no hidden operations.
Rule 5: Security
Client-side AES-256-GCM encryption for sensitive diary entries. Row-Level Security (RLS) ensures each user can only access their own records. TLS 1.3 in transit.
Rule 9: Retention
Clinical assessment data retained for 10 years per NZ health records law. Personal wellness logs deleted on account closure. Users may request deletion at any time.
Rule 11: Disclosure
No individual health data is disclosed to any third party without explicit user consent. Practitioners see only data the user has explicitly shared. No data is sold.
Assessment Conclusion
The privacy risks associated with individual use of Health Compass have been reduced to the lowest "Reasonable Safeguard" level required by NZ law. The architecture is designed so that you are the only person who controls access to your health data. No employer, insurer, family member, or third party can access your records without your explicit action.
This PIA will be reviewed annually or whenever a material change is made to the data architecture. The next scheduled review is April 2027.
Prepared by: QiHub-Health Enterprise Ltd. · Data Processor: BASE44 · Jurisdiction: New Zealand · Governing Law: Privacy Act 2020 & HIPC 2020