Privacy Policy

Who operates ComfortNotes?

ComfortNotes is operated by Homecare Comforts Ltd, trading as Comforts Hearing. ComfortNotes is the product name, not a separate legal company.

Registered company name: Homecare Comforts Limited. Company number: 12224982. Registered office: 65 Seymour Avenue, Morden, Surrey, SM4 4RF, United Kingdom. These pages concern ComfortNotes, not the separate Comforts Hearing clinic website.

Raymond Hill is responsible for ComfortNotes support, security incidents and privacy requests. Contact: info@comforts-hearing.co.uk. Include ComfortNotes and your clinic name. Do not email patient records, photographs, audio, passwords or API keys.

Payments and subscription administration

Stripe provides hosted checkout and the billing portal for ComfortNotes subscriptions operated by Homecare Comforts Limited. Stripe processes the contact, billing and payment details supplied during checkout, transaction information and technical information needed to provide and protect its payment services. ComfortNotes uses clinic/account identifiers, selected plans, Stripe customer and subscription references, payment status and billing events to administer access, renewals, plan changes and billing support. Do not enter patient information into checkout or billing fields.

Card details are entered on Stripe’s hosted pages, not in the clinical notes form. Patient notes, transcripts, photographs and clinical documents are not needed for billing and are not sent as part of the subscription workflow. Authorised billing administrators may access billing information; this does not grant access to patient records.

Billing records are retained as needed for subscription administration, accounting, disputes and applicable legal duties, not deleted automatically when a trial ends or an account closes. The account-specific billing retention schedule still requires confirmation; contact us for a retention or rights enquiry. Stripe also processes information for its own payment, fraud-prevention and legal purposes; see Stripe’s privacy policy. This does not establish verified account-specific supplier or international-transfer arrangements.

Sharing approved documents within your clinic

Consultations remain private by default. Where clinic sharing is enabled, an author may explicitly share a selected approved text document with a named active colleague in the same clinic, including a colleague in another assigned profession. The recipient receives a read-only saved version with its patient/reference and document context, not access to the original consultation, transcripts, source notes or photographs. Clinic administration alone does not grant access to colleagues’ records.

Sharing and access events are recorded for accountability. Later edits to the original do not silently update a previously shared version: review, approve and share the updated version when appropriate. Authors can revoke future access. Disabling clinic sharing blocks viewing and new sharing; re-enabling it restores unrevoked shares. Previously viewed or downloaded copies cannot be recalled. Shared versions and audit history are retained under the clinic’s record and disposal arrangements, not automatically erased by revocation.

The clinic and sharing clinician are responsible for an appropriate care-related purpose, recipient selection, minimum necessary disclosure and applicable patient-information arrangements. Sharing does not send a patient letter automatically or create an Epic connection.

Personal learning and CPD

Where available, the dedicated My learning & CPD page identifies the applicable regulator and registration scope, and saves your chosen profession and topic, learning date and time, answers, reflections, completion status and saved versions separately from patient records. Access through the app is restricted to the account holder, not their clinic administrator. Authorised operational access and backups remain subject to our security arrangements.

Topic suggestions from an approved record are processed in your browser. The CPD service does not receive that record, transcript or patient reference. Optional AI prompts send only the chosen profession, topic and public learning material to OpenAI, with response storage disabled. Personal reflections are not sent to AI. Provider operational retention may still apply. Do not enter identifiable patient information into your learning record.

You acknowledge the storage notice before creating an activity and the separate AI notice before requesting prompts. Saved versions are retained; there is no automatic expiry. Export your learning before account closure and contact support for a verified access or deletion request, including review of backup handling and justified retention. Completion is your declaration of actual learning, not accreditation or guaranteed acceptance by a regulator.

Website contact enquiries

When you submit the contact form, Netlify Forms receives and stores your name, email address, optional clinic name, enquiry type and message for the ComfortNotes team to respond. Enquiries are separate from clinical records and are not sent to AI. Email notifications, when configured, also create a copy in the support mailbox. Access is limited to authorised website and support administrators.

Do not submit patient information, clinical records, recordings, passwords or API keys. No attachments are accepted. Contact-form enquiries follow the support review target of 12 months after closure; deletion is not automatic. Contact info@comforts-hearing.co.uk with questions about an enquiry or your information rights.

Product-support messages

Instant FAQ searches stay in the browser and are cleared when the help box closes. If you choose signed-in chat, your account identity, product-support text, message times, read markers and conversation status are stored separately from clinical records. Only the account holder and authorised ComfortNotes platform-support administrators can access that conversation; clinic administration alone does not grant support access.

Netlify forwards protected chat requests and Supabase stores the messages. Chat does not use AI or email delivery. Please do not include patient details, photographs, credentials or clinical questions. Routine support requests are reviewed 12 months after closure, subject to incident evidence or other justified retention. This is a review target, not automatic deletion.

Information and purposes

The app handles account email addresses, clinic membership and profiles, clinician names, support enquiries and technical session information. Users supply appointment references, notes, transcripts, drafts and optional photographs. Only enter information needed for the consultation and permitted under your clinic’s patient-data arrangements.

These are used to operate accounts and clinic access, save and retrieve work, transcribe recordings, prepare requested drafts and respond to support enquiries. Clinic staff supply appointment information; the app creates document drafts and saved versions from it.

Responsibilities and lawful processing

Homecare Comforts Limited controls account, service administration, support and security information. When Comforts Hearing provides care, the same company controls its clinical information. An independent clinic controls its own patient records; Homecare Comforts Limited processes them on that clinic’s documented instructions under agreed clinic-processing terms.

The owner-approved policy identifies Article 6(1)(f) for staff administration and service security, subject to a documented legitimate-interest assessment. Article 6(1)(b) applies where necessary for a contract with the individual. For the operator’s private care, Article 9(2)(h) also requires the applicable health-care, professional confidentiality and Data Protection Act conditions to be met. Independent clinics must document their own grounds. Recording permission is separate: explain recording and AI use and offer a non-recorded way to document care.

Authorised clinic staff use the live service for clinician-led documentation under their clinic’s patient-data arrangements. This is not a patient self-service portal. The safeguards and operational limitations described here continue to apply.

Providers and AI

Netlify hosts the app and handles protected sign-in sessions and clinical request forwarding; Supabase provides accounts and saved-record storage; AssemblyAI processes audio when it is the configured transcription provider; OpenAI processes notes and transcripts for drafting. The existing OpenAI transcription option remains available for an explicit operational rollback, not an automatic retry. Resend delivers staff account-confirmation and password-recovery emails, not patient letters. When enabled, it also sends clinic trial-activation and expiry-reminder emails containing the clinic name, administrator email address, trial dates and allowances—not patient information. The detailed processing notice explains the current data flow. Otoscopy photo pixels are not sent to OpenAI. Confirmed clinician-written photo findings may support note drafting.

Patient photographs must not be used for training, fine-tuning or a shared reference collection. The app disables OpenAI response storage for drafting; this does not guarantee zero provider retention. UK/EU-only processing has not been established. Provider locations, international-transfer safeguards and contractual details still require final confirmation.

International processing and information requests

UK/EU-only processing is not established for this service. Account-specific supplier entities, processing locations and the applicable transfer arrangements have not all been verified, including the recorded Netlify health-data coverage question. We cannot currently identify a confirmed mechanism for every relevant transfer. This disclosure is not a substitute for establishing lawful supplier arrangements.

Contact info@comforts-hearing.co.uk for the current supplier schedule and copies or explanations of applicable safeguards. An independent clinic must resolve and agree these details before its patient processing begins. This policy does not claim that owner approval alone authorises an international transfer.

Required information and human decisions

Account and clinic information is needed to establish identity and access; without it we cannot provide a signed-in clinic workspace. Photographs and recordings are optional, and care can be documented with typed notes instead. Do not supply unnecessary patient information. AI creates drafts for human review; the service does not make solely automated clinical decisions or automatically send patient letters.

Retention and your choices

The owner approved the retention schedule on 21 September 2026. The adult clinical-record baseline is review eight years after the last relevant care contact or end of treatment, using the later applicable date. This covers relevant notes, transcripts, versions, appointment documents, photographs and reviews. It is a review point, not a universal deletion rule. Active care, complaints, litigation, safeguarding and other preservation duties require a separate decision or hold.

Approved administrative targets are review of unnecessary account/profile information 90 days after closure, cleanup of unnecessary invitation details 30 days after expiry or revocation, 90 days for routine security logs and review of routine support requests 12 months after closure. These are policy targets, not a claim that automated cleanup is deployed. Preserve justified attribution and incident evidence. Do not remove an identity still needed by another authorised service.

Saved consultations retain version history. Archiving is not deletion. No automatic record deletion is enabled. Disposal must check all versions, linked records, photographs, recovery copies and holds; implementation and supplier-specific expiry checks remain outstanding. The patient directory is retained while needed for lawful record linkage.

Raw audio stays in the current browser tab and is sent for requested transcription; it is not saved in the application database. Provider retention may still apply. Stopping recording does not erase a transcript already saved. Closing the tab releases the local audio copy, subject to browser/device recovery behaviour.

Optional audiogram extraction

When you explicitly request audiogram extraction, the selected PDF, JPEG or PNG is sent through the ComfortNotes backend to OpenAI. The whole selected file is processed, including identifiers it contains: remove unnecessary identifiers and use only relevant audiograms. Response storage is disabled in the request, but provider retention rules still apply. Extraction proposes measurements, not a diagnosis. A clinician must verify them before they enter document generation.

The original file is held in the current browser tab only, is not saved in the application database, and is not attached to exports. Retain the original in your clinic record. Entered or extracted measurement drafts, limitations, clinician interpretation and confirmation status save within the consultation under its existing access and retention controls.

Your information rights

Depending on the circumstances, you may have rights to access, correction, erasure, restriction and portability, and to withdraw consent where processing relies on it. You may also have a right to object to processing. Contact info@comforts-hearing.co.uk to make an enquiry; do not attach patient records. Patient-record requests should normally start with the responsible clinic. Identity and authority may need checking, and some records may have to be retained.

You can raise a concern with us and complain to the Information Commissioner’s Office (ICO).

Cookies and browser services

The hosted app uses a protected sign-in session cookie. Current sign-in sessions expire after 30 minutes without a service request or eight hours in total. Work in progress and raw audio may remain in the open tab. Fonts are served locally by ComfortNotes, without browser requests to Google Fonts. Selecting Got it stores a notice-dismissal marker in this tab only, not patient information or consent. See Cookies for names, purposes and durations. These details describe application-managed browser storage; they do not claim to inventory every provider’s internal logs or infrastructure.

Detailed processing notice

Read the existing technical and operational explanation, including recording modes, saved versions and recovery limitations.

Optional Ask the evidence research chat

Available to active clinic members with an assigned Audiology or Physiotherapy workspace. This separate research, reference and education tool searches public web sources; other professions are not enabled. It is not a diagnosis, prescription, emergency service, clinical approval or accredited learning activity. Linked citations and an automated source-audit pass do not guarantee accurate interpretation, complete coverage, access to full text or currency. Check original sources and professional applicability before relying on an answer.

Do not enter patient identifiers or confidential information. No consultation records or transcripts are automatically accessed. User-entered questions and up to three recent completed exchanges pass through the protected service to OpenAI; search queries may reach its search providers. OpenAI response storage is disabled, but provider security and operational retention may apply. ComfortNotes does not save this chat to consultation, CPD or evidence history. It is held in the open research page and clears when you leave that page, change profession, sign out or refresh. Usage counters remain for rate limiting. There is no claim of zero retention or UK-only processing.

The service checks clinic membership and workspace assignment server-side. A shared 20-request hourly limit applies per account; failed attempts may count. Research requests do not consume clinic consultation credits or document AI revisions. This separate allowance does not unlock clinical processing after trial expiry. Access and supplier arrangements remain subject to the clinic’s agreed scope; this notice does not retrospectively amend an existing agreement.