Data handling and compliance

Designed for structural metadata.

The Clinical Engine is intended for study design metadata such as forms, items, variables, codelists, and relationships. It is not a patient-data repository or a clinical record system.

Important scope

Stateless processing is not the same as no compliance obligations.

This page describes the current product intent, not a legal opinion or certification. Applicability depends on the customer, the data submitted, the service configuration, and the jurisdictions involved.

01 / HIPAA

Metadata-only use may avoid PHI

HIPAA generally concerns protected health information handled by covered entities and business associates. Study structure alone is usually not PHI, but an uploaded file containing identifiable patient information may change that analysis. Do not upload PHI or patient identifiers.

02 / FDA 21 CFR PART 11

Intended use determines controls

Part 11 may become relevant when electronic records or signatures are used in a regulated process. A conversion utility should be validated for its intended use, with versioning, repeatable tests, schema validation, access controls, and traceability documented before regulated deployment.

03 / GDPR AND UK GDPR

Personal data can still enter the workflow

GDPR may apply to contact details, account data, IP addresses, support records, or an uploaded file containing personal data. HTTPS, data minimization, retention limits, processor agreements, and a documented rights process remain necessary where applicable.

Pilot readiness checklist

Controls to establish before handling regulated workloads.

  • Display and enforce a no-PHI intake warning
  • Use HTTPS/TLS and document hosting regions
  • Define memory, temporary-file, and log deletion controls
  • Record engine version, input checksum, and conversion result
  • Maintain schema, integration, security, and regression tests
  • Complete customer-specific legal and regulatory assessment

Start with a controlled metadata pilot.

Bring a de-identified or synthetic study specification so the team can review the workflow without exposing patient data.