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Regulatory Compliance

Effective Date: November 26, 2025

Australian Regulatory Classification (TGA)

As an Australian company (AttendMe Pty Ltd, ABN 94 688 321 637), our primary regulatory framework is governed by the Therapeutic Goods Administration (TGA) under the Therapeutic Goods Act 1989.

TGA Exempt CDSS Classification

AttendMe qualifies as an exempt Clinical Decision Support System (CDSS) under Section 14G of the Therapeutic Goods (Excluded Goods) Determination 2018. This classification applies because:

  • Professional Use Only: The software is intended exclusively for licensed healthcare professionals, not patients
  • Does Not Replace Clinical Judgment: All outputs are recommendations and synthesized literature analysis that must be verified and evaluated by healthcare professionals using independent clinical judgment
  • Information Can Be Verified: All responses include full citations to peer-reviewed medical literature, enabling professional verification against primary sources
  • Supports, Not Directs: The software augments clinical decision-making by providing rapid access to medical literature but does not make autonomous clinical decisions

Regulatory Implications

Under TGA regulations, exempt CDSS status means:

  • No ARTG Registration Required: The software is not required to be included in the Australian Register of Therapeutic Goods (ARTG)
  • Ongoing Compliance: We maintain compliance with applicable adverse event reporting and quality management standards consistent with exempt CDSS requirements
  • TGA Oversight: While exempt from registration, the software remains subject to TGA oversight including advertising standards and post-market surveillance

New Zealand Regulatory Classification (Medsafe)

In New Zealand, medical devices are regulated by Medsafe under the Medicines Act 1981. AttendMe is classified as non-device software under Medsafe guidelines because:

  • Information Tool: AttendMe provides literature synthesis and research support, not diagnosis, treatment, or monitoring functions
  • Professional Verification Required: All outputs require independent professional verification against cited primary sources
  • No Patient Interface: The software is designed for healthcare professional research, not direct patient care or patient-facing use

AttendMe is not required to be notified in the WAND (Web Assisted Notification of Devices) database as it does not meet the definition of a medical device under New Zealand law.

New Zealand Privacy: AttendMe complies with the Privacy Act 2020 and the Information Privacy Principles (IPPs), including the Health Information Privacy Code 2020 where applicable.

United States Regulatory Classification (FDA)

In the United States, the FDA regulates software as a medical device under the Federal Food, Drug, and Cosmetic Act. AttendMe qualifies as Non-Device Clinical Decision Support (CDS) software under the 21st Century Cures Act, Section 3060(a).

21st Century Cures Act Criteria

AttendMe meets all four criteria for Non-Device CDS exclusion:

  • Criterion 1: Does not acquire, process, or analyze medical images, IVD device signals, or signal acquisition system patterns
  • Criterion 2: Displays, analyzes, or prints medical information (synthesized literature and evidence summaries)
  • Criterion 3: Intended for supporting or providing recommendations to healthcare professional users
  • Criterion 4: Enables healthcare professionals to independently review the basis for recommendations (full citations provided) so they do not rely primarily on the software

As Non-Device CDS software, AttendMe is excluded from the FDA medical device definition and is not subject to FDA premarket review requirements (510(k), De Novo, or PMA).

HIPAA Compliance (US Healthcare Providers)

For healthcare providers operating in the United States, AttendMe maintains HIPAA-aligned security measures to protect healthcare information. While AttendMe is designed as a research tool and is not intended to process Protected Health Information (PHI), we implement safeguards consistent with HIPAA requirements:

  • Administrative Safeguards: Security officer designation, risk assessment procedures, incident response planning
  • Physical Safeguards: SOC 2 Type II certified cloud providers with secure data centers
  • Technical Safeguards: Encryption (TLS 1.3, AES-256), access controls, audit logging

Business Associate Agreements (BAAs) are available for healthcare organizations requiring formal HIPAA compliance documentation.

Privacy Commitment

AttendMe is committed to protecting the privacy and security of our users' information. While AttendMe is designed as a research tool and users should not input Protected Health Information (PHI), we maintain HIPAA-compliant security measures as part of our commitment to healthcare data protection.

Important Notice About PHI

How We Protect Your Information

Even though PHI should not be entered into our system, we implement comprehensive security measures:

  • Physical Safeguards: Secure data centers with controlled access
  • Technical Safeguards: Encryption, access controls, and audit logs
  • Administrative Safeguards: Employee training, access policies, and security procedures

Security Measures

Encryption

  • All data transmitted between your device and our servers is encrypted using TLS 1.3
  • Data at rest is encrypted using AES-256 encryption
  • Encryption keys are managed using industry best practices

Access Controls

  • Role-based access control (RBAC) for all system components
  • Multi-factor authentication available for user accounts
  • Regular access reviews and privilege audits
  • Automatic session timeouts for inactive users

Audit Logging

  • Comprehensive logging of all data access and modifications
  • Tamper-proof audit trails
  • Regular review of access logs
  • Retention of audit logs for minimum of 6 years

User Rights and Responsibilities

As a user of AttendMe, you have the right to:

  • Access your account information and usage history
  • Request corrections to your account information
  • Request deletion of your account and associated data
  • Receive notifications of any security breaches
  • File a complaint if you believe your privacy rights have been violated

Your responsibilities include:

  • NOT entering any PHI or patient-identifiable information
  • Maintaining the security of your account credentials
  • Reporting any suspected security incidents immediately
  • Using the service only for its intended research purposes

Business Associate Agreements

While AttendMe is not intended to handle PHI, we are committed to establishing Business Associate Agreements (BAAs) with service providers who handle user data. BAAs are available upon request for healthcare organizations requiring formal HIPAA compliance documentation.

Our infrastructure providers (Supabase, Vercel, OpenAI, Sentry) maintain SOC 2 Type II certifications. We pursue BAAs with these providers as part of our ongoing compliance program.

Breach Notification

In the unlikely event of a data breach, we will:

  • Notify affected users within 72 hours of discovery
  • Provide details about what information was involved
  • Describe steps we are taking to investigate and mitigate
  • Offer guidance on protective measures you can take
  • Comply with all applicable breach notification laws

Workforce Training

All AttendMe employees and contractors with access to user data receive:

  • Initial HIPAA privacy and security training
  • Annual refresher training
  • Role-specific security training
  • Regular updates on privacy best practices

Compliance and Auditing

We maintain our security posture through:

  • Regular security risk assessments
  • Use of SOC 2 Type II certified infrastructure providers
  • Continuous security monitoring via automated tools
  • Dependency vulnerability scanning
  • Continuous improvement of security measures

Independent penetration testing and third-party security audits are planned as part of our security roadmap.

Questions and Complaints

If you have questions about our privacy practices or believe your privacy rights have been violated:

You also have the right to file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights:

www.hhs.gov/ocr/privacy/hipaa/complaints/

Changes to This Notice

We reserve the right to change this notice and our privacy practices. Any changes will be posted on our website and will apply to all information we maintain. The effective date of the notice is listed at the top of this page.

Remember:

AttendMe is a research and educational tool. Never input patient-identifiable information. Always maintain patient privacy in accordance with your professional obligations and applicable laws.