PreSAGE Data Protection Policy

Last updated	17th April 2025

DEFINITIONS

Term	Definition
PreSAGE	The AI-powered, non-contact fall prediction and detection system developed by CoNEX Healthcare Pte Ltd, utilizing thermal imaging and machine learning.
Client	Any hospital, aged care facility, institution, or individual that contracts with CoNEX Healthcare to deploy and use PreSAGE.
Thermal Imaging Data	Low-resolution, heat-based images captured by PreSAGE devices. These do not include facial features, skin tone, clothing, or other visual identifiers.
Playback Data	Thermal imaging snapshots stitched into short video clips for incident review or behavioral analysis.
Operational Data	Non-personal system data such as device status, uptime logs, software events, and alerts used for diagnostics and performance monitoring.
Access Logs	Records of user login attempts, access to system functions, configuration changes, and support activity.
On-Premise Storage	Client-managed local data storage infrastructure within their own IT network or premises.
Cloud Storage	Data storage provided by CoNEX Healthcare through secure AWS Sydney-based cloud infrastructure, used with client consent.
Virtual Machine (VM)	A secure, client-controlled computing environment that allows limited PreSAGE support access to systems for troubleshooting and configuration.
Australian Privacy Principles (APPs)	A set of 13 principles under the Privacy Act 1988 (Cth) that govern the handling of personal information by Australian government agencies and certain private sector organizations.
Edge Processing	Processing that occurs locally on the PreSAGE device itself, rather than transmitting raw data to external servers.
Sensitive Information	As defined under the Privacy Act, includes health information or other personal data that requires higher levels of protection. PreSAGE does not collect or process such information by default.
Subprocessor	A third-party service provider engaged by CoNEX Healthcare to support infrastructure (e.g., AWS), with no access to identifiable data unless approved by the client.

1. Purpose of This Policy

This Privacy and Data Protection Policy is intended to provide transparency into how PreSAGE handles, protects, and governs data collected during the course of system deployment and operation. As a healthcare-facing technology provider operating within Australia, CoNEX Healthcare recognizes the importance of aligning with both regulatory requirements and the expectations of clients, caregivers, and patients. The policy sets out our compliance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), while also detailing specific practices tailored for hospital, aged care, and home-based deployments.

3. Overview of the PreSAGE System

PreSAGE is an AI-driven fall prevention solution that uses thermal imaging to detect and predict bed-exit behavior—one of the leading causes of falls in hospitals and aged care environments. The system does not use standard video cameras or any RGB technology; instead, it generates low-resolution thermal heat maps that capture only the shape and temperature variation of the person. It offers edge-based image processing, meaning the raw image data is processed locally on the device itself. Optionally, PreSAGE can integrate with Bluetooth presence tags to detect the proximity of caregivers, further enhancing accuracy by reducing false alarms.

No facial features, skin tones, clothing patterns, or personally identifying images are ever recorded or stored.

4. What Data Is Collected and Why

PreSAGE does not collect personal health information by default. However, in order to provide its intended functionality, certain data types may be collected with client consent:

Thermal Imaging Playback Data: This consists of non-identifiable thermal silhouettes recorded during specific events (e.g., bed-exit attempts or alerts) for review by clinical staff. These are stored only when clients opt-in.
System Logs and Alert History: These logs include timestamps of system status updates, uptime, device alerts, and internal error reporting for support and performance monitoring.
Access Logs: The system records all administrator access events and configuration changes to support auditability and incident tracing.
Bluetooth Tag Presence Data (if enabled): A randomly generated, non-identifiable token associated with caregiver tags. This is used only to suppress alarms if a staff member is present during a bed-exit attempt.

Metadata such as timestamps and location identifiers may also be logged for contextual accuracy, but such information is anonymized and not linked to any patient identifier or health record.

6. Data Storage Options

PreSAGE offers two distinct modes of data storage based on client preference:

On-Premise Storage: All data, including playback and logs, is stored within the client’s IT-controlled environment. CoNEX Healthcare accesses the system only via a secure virtual machine controlled by the client for troubleshooting or update deployment.
Cloud Storage: PreSAGE may store data in AWS cloud infrastructure located in Sydney, Australia. All data is encrypted at rest and in transit using modern encryption standards (AES-256 and TLS 1.2+), and access is tightly controlled through role-based permissioning.

All data is owned by the client at all times. PreSAGE merely acts as a data processor, operating only within the scope of access explicitly granted by the institution.

7. Data Access and Sharing

PreSAGE does not access any data unless the client institution has explicitly authorized it. Access may be granted for:

Technical support under a signed service agreement
Data-driven collaboration under a research or trial agreement

In both cases, access is controlled through a client-managed VM or system proxy. No data is shared with third parties for commercial purposes. Subprocessors, such as AWS, operate purely as infrastructure providers and are contractually prohibited from accessing or using stored data in any way.

8. Data Retention and Deletion

All data collected is retained only for the duration specified by the client. The default retention period for playback videos and logs is 30 to 90 days, but this can be configured based on internal policy, contractual requirements, or regulatory obligations. Upon termination of the service, clients may request a full export of all system data prior to deletion. All deletion events are logged, and confirmations are provided.

9. Regional Privacy Compliance

PreSAGE is fully aligned with the Australian Privacy Principles (APPs) and complies with the Privacy Act 1988 (Cth) as well as any applicable state-based privacy regulations, such as Victoria’s Health Records Act 2001. The system does not capture, process, or transmit personally identifiable or sensitive health information without institutional consent.

10. Data Security and Safeguards

PreSAGE is built with multiple layers of technical protection:

AES-256 encryption at rest, TLS 1.2+ in transit
Role-based access and audit logs
OAuth2/OIDC integration (e.g. Azure AD, Okta)
Local edge processing ensures raw thermal data never leaves the device
Cloud: Protected by continuous threat monitoring
On-premise: Follows institutional IT policies

12. Business Continuity and Patch Protocol

BCP plans are in place for high availability and support.

All updates, patches, and AI model improvements follow a version-controlled release cycle. Clients are notified in advance of major changes and can request deferred deployment. Emergency patches are rolled out only with approval or through pre-defined IT protocols.

CoNEX Healthcare Pte Ltd