Last updated: APR 2026

This Privacy Policy describes how Vensa Health Limited (“Vensa”, “we”, “us” or “our”) collects, uses, discloses, stores, and protects personal information (including health information) in accordance with:

The Privacy Act 2020
The Health Information Privacy Code 2020 (“HIPC”)

By using our website, applications, products, or services (the “Services”), you acknowledge that you have read and understood this Privacy Policy.

If you do not agree, you should not use our Services.

1. OUR ROLE AND COMMITMENT TO PRIVACY

1.1 Our Role

Vensa provides a secure digital platform that enables patients to interact with their healthcare providers (“Health Providers”).

Your Health Provider’s clinical system (PMS) remains the official clinical record and record of truth. Vensa does not replace or override your provider’s clinical record.

1.2 Our Commitment

We are committed to safeguarding personal information in accordance with the Privacy Act 2020 and HIPC.

We will only collect, use, disclose, and retain personal information:

For lawful and legitimate purposes
To the extent reasonably necessary to provide the Services
In accordance with principles of transparency, fairness, and security

2. WHAT INFORMATION WE COLLECT

We collect and process personal information to provide and support the Services.

Some information is required for account functionality and security. If you do not provide required information, certain Services may not be available.

2.1 Categories of Information Processed Through the Portal

Category	Examples	Retention Within Portal	Legal Basis
Identity & Account Information	Name, date of birth, NHI, email, mobile	Retained for account operation and identity matching	Necessary to provide the Services (IPP1; HIPC Rule 1)
Lab & Radiology Results	Laboratory results, imaging reports	May be retained if enabled by your Health Provider and permitted by your portal privacy settings	Necessary for Health Record features; transparency under IPP3 / Rule3
Clinical Notes	Consultation notes, discharge summaries	May be retained if enabled and permitted	As above
Medications	Current and historical medication lists	May be retained if enabled and permitted	As above
PMS Classifications	Diagnoses, conditions, problem lists	May be retained if enabled and permitted	As above
Operational & Service Records	Appointment bookings, prescription requests, secure messages, payment confirmations, support interactions	Retained as necessary to deliver Services, support continuity, enable auditability, and meet governance and legal obligations	Necessary for service delivery and lawful operation (IPP1, 10; HIPC Rules 9–11)
Security & Audit Logs	Login history, IP address, device/session metadata, access logs	Retained for system security, fraud prevention, monitoring, and compliance	Security and integrity obligations (IPP5, 10)
Technical & Usage Data	App usage metrics, device type, crash diagnostics	Retained for reliability and service improvement; de-identified or aggregated where reasonably practicable	Service improvement and security (IPP5, 10)

2.2 Sources of Information

We collect information from:

You, when you create or manage your account or use the Services
Your Health Provider, where necessary to provide portal functionality and subject to your privacy settings and provider configuration
Authorised representatives acting on your behalf (e.g., parent, guardian, attorney)

2.3 Children and Authorised Representatives

Where a representative acts on behalf of another person, we may take reasonable steps to confirm authority consistent with HIPC and the Code of Health and Disability Services Consumers’ Rights.

2.4 Aggregated and De-Identified Data

We may generate aggregated or de-identified datasets for service improvement, reporting, and system performance monitoring. We will not knowingly re-identify such data except where permitted or required by law.

3. PURPOSES FOR USE OF PERSONAL INFORMATION

We use personal information only for legitimate purposes connected with the operation of the Services, including:

Providing and administering user accounts
Facilitating appointments, prescriptions, messaging, and payments
Displaying Health Record features (where enabled)
Verifying identity and protecting account security
Maintaining audit trails and system integrity
Improving service reliability and performance
Complying with legal and regulatory obligations
Responding to lawful requests or investigations
Conducting ethically approved research in accordance with HIPC Rule 11 (only in de-identified or authorised contexts)

We do not use identifiable health information for advertising.

4. DISCLOSURE OF PERSONAL INFORMATION

We may disclose personal information:

To your Health Provider as required to deliver Services
To trusted service providers (e.g., hosting, communications, support tooling, payment processors) under contractual confidentiality and security obligations
To regulatory or enforcement agencies where required by law

We do not sell identifiable health information.

5. OVERSEAS STORAGE AND TRANSFERS

We host personal information using Microsoft Azure data centres located in Australia.

Where information is disclosed or made accessible overseas, we take reasonable steps to ensure comparable safeguards consistent with IPP12, including contractual and security controls.

6. SECURITY AND SAFEGUARDS

We implement safeguards appropriate for health information, including:

Role-based access controls
Multi-factor authentication for privileged access
Encryption in transit and at rest
Monitoring and logging
Least-privilege access review
Security testing and vulnerability management

While no system is completely immune from risk, we take reasonable steps to reduce and manage risk.

7. RETENTION AND DELETION

7.1 Clinical Records (Health Provider Responsibility)

Your Health Provider is responsible for retaining clinical records in accordance with applicable health record retention regulations.

7.2 Portal Information Retention

We retain personal information for as long as reasonably necessary to:

Provide the Services
Maintain operational continuity
Support auditability and governance
Meet legal, contractual, and regulatory obligations

7.3 Health Record Feature Retention

Where Health Record features are enabled and retention is permitted by your portal settings:

Certain clinical information may be securely retained within your portal account to support functionality.
If you withdraw consent or disable storage (where available), we will cease further retention for that category.
Removal of previously retained portal copies is initiated and executed in accordance with our retention and backup processes.

7.4 Operational and Security Logs

Operational records and security logs may be retained for reasonable periods to:

Detect and prevent fraud or misuse
Investigate incidents
Resolve disputes
Comply with legal obligations

7.5 Account Closure

When your account is closed or your use of the Services ends:

Personal health information held within the Vensa portal is no longer retained for active service delivery purposes.
We retain personal information only for as long as reasonably necessary to:
- complete any outstanding operational or service activities;
- maintain appropriate audit, security, and system integrity records;
- comply with legal, regulatory, or contractual obligations.
Where information has been retained within the portal as part of Health Record features (and subject to your privacy settings), removal of those portal-held copies is initiated and carried out in accordance with our retention and backup processes.
Your Health Provider remains responsible for retaining the official clinical record within their practice management system in accordance with applicable health record retention requirements.

We do not retain personal information indefinitely following account closure. Any residual retention is limited, purpose-based, and subject to legal and appropriate safeguards.

8. YOUR RIGHTS

You have the right to:

Request access to personal information we hold about you
Request correction of personal information

Clinical corrections should generally be requested through your Health Provider. Vensa will reflect updates via portal synchronisation.

Requests may require identity verification.

9. NOTIFIABLE PRIVACY BREACHES

If we experience a notifiable privacy breach (where serious harm is likely), we will notify:

Affected individuals as soon as practicable
The Office of the Privacy Commissioner, as required by law

Where appropriate, we may also notify your Health Provider and relevant sector bodies.

10. YOUR PRIVACY CONTROLS

Where supported by your Health Provider configuration, you may manage privacy settings within the portal, including whether specific categories of health information are retained for Health Record features.

If disabled, information may still be retrieved from your Health Provider’s system for display, but may not be retained within the portal.

Operational and security records necessary for service delivery are not controlled by these toggles.

11. CHANGES TO THIS POLICY

We may update this Policy from time to time to reflect legal, operational, or technological changes.

Where changes are material, we will take reasonable steps to notify users.

Continued use of the Services constitutes acknowledgment of the updated Policy.

12. CONTACT US

Privacy Officer
Vensa Health Limited
PO Box 8349, Symonds Street, Auckland, New Zealand
Phone: 0800 736 463
Email: support@vensa.com