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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:

  • role declarations,

  • access requests,

  • account information,

  • non-clinical organizational data,

  • governance acknowledgements,

  • 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:

  • explicit,

  • consent-based,

  • clearly separated from governance functions.

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