Privacy policy
This is a draft awaiting legal review — see the highlighted gaps below, and treat this page as not-yet-final until they're resolved.
Who we are
Portfolio Pathways is a trading name of Understand My Health Ltd (“we”, “us”), a company registered in England and Wales. We provide a platform to help doctors prepare evidence for the GMC's Portfolio Pathway (CESR/CCT route to specialist registration). This policy explains what we collect, why, and what rights you have over it.
Understand My Health Ltd, 414 Wimbledon Park Road, London. Data protection contact email still to be added.
What we collect
Account information: name, email address, and password (stored securely; we never see your password in plain text).
Portfolio evidence: documents you upload (certificates, logbooks, assessments, reflections, and similar), along with information you enter about them — descriptions, institution names, dates.
Profile information: your specialty, career history relevant to your application, and referee contact details you choose to add.
Payment information: handled by Stripe — we do not receive or store your full card details ourselves.
Usage information: basic technical data (login times, browser type) needed to keep the service secure and working properly.
Why we collect it
We use your information only to:
- Provide the core service — categorising, scoring, and organising your evidence against GMC requirements
- Generate the documents you ask us to produce (proformas, section summaries)
- Maintain your account and process payment for your subscription
- Respond if you contact us
- Keep the platform secure and fix problems when they occur
We do not sell your information, and we do not use your documents to train AI models beyond what's needed to provide the service to you.
Where your data is processed
Document storage and your account: held with Supabase, our database and storage provider, hosted in the UK (AWS eu-west-2, London).
Automated processing:when you upload a document, its content is sent to Anthropic's Claude API to categorise it, assess its quality, and help map it to GMC requirements. This is processing on our behalf, under Anthropic's own data handling terms for API usage — your documents are not used to train Anthropic's models.
Anthropic's API, used for document processing, may process data outside the UK/EEA as part of its infrastructure. Confirm Anthropic's current data processing terms and which international transfer safeguard applies (e.g. the UK's International Data Transfer Addendum to the EU Standard Contractual Clauses) before this goes live.
AI processing of your documents
Analysing a document means reading it, so your uploads are transmitted to our AI processing provider (Anthropic) over an encrypted connection and processed under contractual data-protection arrangements. They are not processed by us manually, and no human at Anthropic reads them in the ordinary course of the service.
The analysis produces a suggested category, a draft description and a judgement about what the evidence demonstrates. All of it is a suggestion: nothing is added to your portfolio until you confirm it, and you can edit or discard any of it.
Privacy screening and anonymisation
You are responsible for permanently removing patient-identifiable information from your evidence before upload, in line with current GMC guidance. Portfolio Pathways does not provide a substitute for that redaction.
Before a general evidence document is sent to Portfolio Pathways, our privacy screening tool checks extractable text locally in your browser for information that may need to be removed. The screening happens on your device before the upload request is made. If the screen identifies a potential issue, you must review it before proceeding.
The screening tool is an additional safeguard and cannot guarantee that every identifier will be detected. You must confirm that you have reviewed the document and that it is appropriately anonymised before the server will accept the upload. Files that cannot be screened reliably must be made readable before they can be uploaded through the general evidence flow.
How long we keep your data
Portfolio evidence and account data:kept for as long as your subscription is active, plus 90 days after cancellation in case you wish to reactivate without re-uploading everything. After that, it is permanently deleted. You can request earlier deletion at any time — see “Your rights” below.
Billing records: UK tax law requires financial records (invoices, payment records) to be kept for 6 years regardless of when your account is closed — this is a separate legal minimum, not a GDPR consideration, and applies even if you delete your account or request erasure of everything else.
Contact form messages: kept for 12 months, then deleted, unless a message becomes part of an ongoing conversation with you.
These periods follow UK GDPR's storage limitation principle — keep personal data no longer than necessary for the purpose — alongside HMRC's separate 6-year requirement for financial records. Have a solicitor confirm these periods before publishing, particularly given the professional and health-adjacent nature of the evidence involved.
Who else sees your data
- Supabase and Anthropic: our storage/authentication and document processing providers respectively, acting as processors on our behalf under their own data processing terms.
- Our payment processor: for billing only.
- The GMC: we do not share your evidence, profile, or documents with any GMC system, third party, or other user. Submission to the GMC remains something you do yourself, outside this platform.
- Legal authorities: we will disclose information if legally required to do so.
Your rights (UK GDPR)
You have the right to access, correct, delete, or export your data, object to certain processing, and withdraw consent where processing relies on it.
To exercise any of these, contact us at data protection contact email — same one to be added under “Who we are”. You also have the right to complain to the Information Commissioner's Office (ico.org.uk) if you believe we have mishandled your data.
Cookies
This platform currently uses only essential cookies required for login and security — no analytics or advertising cookies are in use.
Confirmed future need (not yet built): when analytics tooling is added, this section needs updating AND a real cookie consent banner needs building alongside it — UK PECR requires active consent before non-essential cookies are set, which a policy-text change alone doesn't satisfy. This line is only accurate as of today's build..
Changes to this policy
We will update this policy if how we handle data changes, and we will notify you by email.
Last updated: date