Data Processing Agreement (DPA)

Last updated: 29 May 2026 · Effective from your subscription start date

This Data Processing Agreement ("DPA") forms part of the Terms of Service between CareO ("Processor") and the Customer Hospital ("Controller / Data Fiduciary"). It governs the processing of personal data, including sensitive personal data (health data) under the Digital Personal Data Protection Act 2023.

1. Roles

The Hospital is the Data Fiduciary for patient data and is responsible for obtaining valid consent. CareO acts only as a Data Processor, processing data on documented instructions from the Hospital, as embodied in the Service.

2. Subject-matter & duration

Processing covers the operation of the Service for the term of the subscription, plus a 60-day post-termination data-retention window for export.

3. Nature & purpose

Storing, organising, retrieving, transmitting and erasing personal data necessary for clinical documentation, billing, statutory reporting, security and customer support.

4. Categories of data subjects

Patients (incl. minors via guardian), hospital users (doctors, optometrists, nurses, billing, admin, super-admin).

5. Sub-processors

Hosting (AWS / Emergent platform), database (MongoDB Atlas), SMTP (Gmail Workspace), payment (Razorpay / PayU), SMS (MSG91 / TextLocal). All sub-processors are bound by equivalent confidentiality and security obligations. We notify Customers of any new sub-processor 30 days in advance.

6. Security measures

TLS 1.2+ in transit; bcrypt + AES (Fernet) at rest for credentials & 2FA secrets; per-tenant database isolation; role-based access control; audit logs; 99.5% uptime target; encrypted off-site daily backups with 30-day retention.

7. Breach notification

We will notify the Hospital and (where required) the Data Protection Board of India within 72 hours of becoming aware of a personal-data breach, providing nature of breach, categories & approximate number of records affected, and mitigation measures.

8. International transfers

All primary data is hosted in India. Disaster-recovery snapshots may briefly transit through Singapore / EU regions with equivalent contractual safeguards in place.

9. Data-subject rights assistance

We provide tooling (CSV / JSON export, deletion API) so the Hospital can fulfil access, correction, portability and erasure requests within the timelines mandated by the DPDP Act.

10. Audit

The Hospital may, with reasonable notice and during business hours, audit our compliance with this DPA — including third-party reports, ISO/SOC certifications when available — once per year.

Questions? Write to info@stewardindia.com · CareO · EMR for Eye Care · powered by Steward Healthcare India Pvt Ltd