DATA ROLE SEPARATION STATEMENT
Last updated: 22/03/2026
1. Governance Role
SmilePerfection.HDBC IKE operates as a governance and access entity.
2. Framework-Level Data
SmilePerfection.HDBC may process non-clinical framework-level data, such as:
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role declarations,
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access requests,
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account information,
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non-clinical organizational data,
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governance acknowledgements,
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technical usage data.
3. Clinical Data
Clinical records, diagnosis, treatment plans and healthcare documentation remain outside the ordinary role of SmilePerfection.HDBC and must remain under the responsibility of the licensed provider or clinic controlling care delivery.
4. No Assumption of Clinical Controller Role
SmilePerfection.HDBC does not present itself as controller of clinical care records and does not assume professional responsibility for clinical decision-making.
5. Consent and Transition
Where any transition from non-clinical governance processes toward independent care occurs, such transition must be:
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explicit,
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consent-based,
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clearly separated from governance functions.
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