Security and POPIA
How ATTEND handles patient records, written for the person who has to check. Where something is a design commitment rather than a deployed fact, this page says so.
Roles under POPIA
The practice
Responsible party. The practice decides what is processed and why, and remains the party the patient has a relationship with.
flowxscale
Operator under sections 20 and 21. We process records only on the practice's instructions, under a written operator agreement signed before any record is processed. flowxscale LLC is a Delaware company; its principal place of business, and the place from which ATTEND is administered, is Cape Town.
Infrastructure provider
Sub-operator. Named in the operator agreement, with the operator's obligations flowed down. Any change of sub-operator requires notice to the practice and its consent.
Where records are processed and stored
Location
ATTEND is designed so that patient records are stored and processed in South Africa. The production environment is being deployed on this basis, and the operator agreement records the location and any change to it.
Isolation
The design gives each practice its own isolated environment, with no shared database and no shared credentials between practices. A misconfiguration in one cannot expose another.
Encryption and backups
Records are encrypted at rest. Backups are continuous and encrypted, and restoring from them is rehearsed as a drill, not only attempted in an emergency.
Cross-border transfers
No transfer of patient records outside South Africa is part of the design. One optional feature sends a photograph of a hospital patient label to an AI vision service outside South Africa; it operates only with the patient's explicit, recorded consent, and every operator agreement discloses it as the sole exception.
Access
Accounts
Each doctor and staff member has their own account. Passwords are hashed with argon2id. Two-factor authentication with an authenticator app is mandatory for every account, not optional.
Roles
Access is by role: doctors, practice staff and administrators each see what their work requires.
Where staff work from
Staff sign in from wherever they work — the consulting rooms, the hospital, or abroad — over HTTPS with two-factor authentication. Responses are marked not to be cached by the browser.
Identifiers and logging
Identity numbers
A South African identity number is validated and then hashed with a keyed secret before it is stored. The raw number is never stored, logged or included in a report file.
Report identifiers
Each report carries a unique identifier in its footer. Because it contains the patient's name, ATTEND treats it as patient data everywhere: it never appears in logs or error messages.
Logs
Logs record the names of fields, counts and hashes — never the values. There is no analytics, telemetry or crash reporting inside ATTEND.
Doctor signing keys
Each doctor has a cryptographic signing key, generated and held on the system and never exported, so a signed report can be verified as theirs.
Continuity and exit
Written into every operator agreement:
- No lock-out. There is no licensing switch in ATTEND; billing is handled outside the system, and access to records is never withheld over an invoice.
- Return of data on termination, in a usable form. This obligation survives non-payment.
- A monthly export held by the practice, including the key needed to interpret pseudonymised identifiers, so the practice is never dependent on us to read its own records.
- Breach notification to the practice within 72 hours.
- An annual written security report.
- Sub-operators listed by name, with the practice's consent required for any change.
- South African law and forum, and submission to the Information Regulator.
This website
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Questions
Write to hi@flowxscale.com. The operator agreement and a security summary are available to any practice considering ATTEND.