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Open Book Clinical/Governance/Sub-processor Register
Data Governance

Sub-processor Register

A complete list of third-party sub-processors engaged by OpenBook Clinical Pty Ltd (ABN 38 698 494 656) to process personal data in the course of delivering the OpenBook Clinical service.

Last updated: 1 July 2025Governing law: New South Wales, Australia
For DPA customers: This register forms part of the Sub-processors schedule to OpenBook Clinical's standard Data Processing Agreement. You will receive 30 days' notice of any additions or replacements. To subscribe to change notifications, email openbookclinical@gmail.com.

Sub-processor Register

The following sub-processors are currently authorised to process personal data on behalf of OpenBook Clinical. All sub-processors are bound by data processing terms that impose equivalent obligations to those in our standard DPA.

Sub-processorFunctionLocationData AccessedData RetentionCertification
Supabase Inc.Security page ↗Database, authentication, file storageAustralia (ap-southeast-2, Sydney) + US (headquarters)User accounts, search logs, CPD records, session dataPer data retention schedule; deleted within 60 days of account closure on requestSOC 2 Type II
Anthropic PBCSecurity page ↗AI processing (Claude API) — query synthesis and evidence retrievalUnited StatesSearch query text only; no account data or patient data0 days — zero-data-retention agreement; queries are not stored or used for model trainingSOC 2 Type II
Vercel Inc.Security page ↗Web application hosting, CDN, serverless functionsGlobal (primary: United States; edge nodes worldwide)Request logs (IP address, request headers, response metadata)30 days (request logs); no personal data stored at edgeSOC 2 Type II
Stripe Inc.Security page ↗Payment processing, subscription management, invoicingUnited StatesBilling name, email address, payment method token (no full card numbers stored by OpenBook Clinical)Per Stripe data retention policy; billing records retained 7 years per Australian tax lawPCI DSS Level 1
Postmark (ActiveCampaign)Security page ↗Transactional email delivery (account notifications, billing receipts, password resets)United StatesRecipient email address, email content (transactional only)45 days (message logs)SOC 2 Type II

Change Notification

OpenBook Clinical will notify customers of any intended additions or replacements to the sub-processor list with not less than 30 days' notice prior to the change taking effect. Notification is provided by:

  • Email to the account holder's registered email address
  • Update to this page with a changelog entry
  • Where a DPA is in place, direct notification to the nominated privacy contact

Customers who object to a proposed sub-processor change may raise their objection in writing to openbookclinical@gmail.com within the 30-day notice period. Where an objection cannot be accommodated, the customer may terminate their subscription in accordance with the Terms of Service.

To receive sub-processor change notifications by email, subscribe at openbookclinical@gmail.com.

International Data Transfers

Some sub-processors (Anthropic, Vercel, Stripe, Postmark) are located in the United States. Where personal data is transferred outside Australia, OpenBook Clinical relies on one or more of the following transfer mechanisms:

  • Adequacy determination: Where the destination country has been assessed as providing an adequate level of protection under Australian privacy law.
  • Contractual safeguards: Standard contractual clauses or data processing agreements that impose equivalent obligations to Australian Privacy Principle 8.
  • Zero-data-retention: For Anthropic (AI processing), a zero-data-retention agreement ensures that no personal data is stored on Anthropic's systems following processing. Query content is transmitted securely and immediately discarded.

The Anthropic zero-data-retention agreement is the primary safeguard for AI query processing. A summary of its key terms is published in the AI Governance Framework.

Questions about sub-processors?

For enquiries about our sub-processor arrangements, to subscribe to change notifications, or to request additional documentation for your institutional procurement process, contact our privacy team.

openbookclinical@gmail.com

OpenBook Clinical Pty Ltd · ABN 38 698 494 656 · Sydney, NSW, Australia