Procurement document

Compliance roadmap

Current state and trajectory against four standards: ISO/IEC 27001:2022, ISO 27799 (healthcare overlay), AICPA SOC 2 Type II, and the NHS Data Security & Protection Toolkit. Plus the Data Processing Addendum framework, sub-processor list with EU-region designations, and cross-border data-transfer mechanisms. Save as PDF (⌘P / Ctrl+P) for your compliance officer.

Document version: 2026-05-14 · Latest version always at medicarehis.com/compliance-roadmap

Headline

Where we are, in one paragraph

MediCare HIS is not yet formally certified to any external standard. We've done the work to be measurable against them — gap analyses with per-control evidence are maintained in our internal controls inventory and made available to procurement / audit teams under NDA — and we are progressing through formal certification on a Stage-gated cadence. The honest framing: we hold more compliance evidence than most local vendors, less than fully-certified enterprise vendors. The trajectory below is what we commit to deliver.

By standard

Four standards, four trajectories

ISO/IEC 27001:2022

Current state: Pre-certification gap analysis maintained. ~80% of technological controls (Annex A.8) met by implemented controls with per-control evidence (available under NDA). Organisational and people controls addressed at the level appropriate to founder-led Stage 1.

Trigger to certify: First paying customer (Stage 1 end) opens auditor selection. 12-month observation window through Stage 2. Type I assessment at end of Stage 2.

Expected timeline to formal cert: 18–24 months from first paid customer.

Evidence today: Annex-A control mapping published; pen-test scope finalised and engagement scheduled; quarterly committee minutes pattern established.

ISO 27799:2016 (healthcare)

Current state: Per-theme mapping published covering PHI confidentiality / integrity / availability / auditability, patient consent and rights, patient identification (cross-tenant 404 isolation), role-based clinical access, audit log retention, integration security, backup, personnel.

Trigger to certify: First teaching hospital deployment typically opens 27799 conversations.

Expected timeline: Tracks 27001 certification (typically done together).

Differentiator: Most African HIS vendors do not produce a 27799 mapping at all. Publishing one places us in a different conversation with healthcare buyers and their auditors.

AICPA SOC 2 Type II

Current state: Roadmap defined. Security (mandatory) + Availability + Confidentiality TSCs in scope at Stage 1. ~80% of the SOC 2 control population is already met by implemented controls — the remaining work is largely evidence-collection cadence rather than missing controls.

Trigger: First international or insurance-integrated customer.

Expected timeline to Type II report: 30–42 months from first paid customer (Stage 2 audit-readiness, then Stage 3 12-month observation window).

Sequencing rationale: ISO 27001 first because African and European customers ask for that. SOC 2 second because international (US/UK) customers ask for that. Both cover similar ground; the work compounds.

NHS Data Security & Protection Toolkit

Current state: Standard-by-standard mapping published. 9 of 10 National Data Guardian standards effectively met today. The 10th (annual training records) closes at Stage 2 hiring.

Trigger: Not certifying — we are not an NHS supplier. Mapping serves as the strongest signal we can offer on healthcare-specific security maturity for African and donor-funded buyers.

Why it matters: NHS is the most evolved healthcare security context in the world (active iteration after real incidents like WannaCry). Being measurable against it is a meaningful signal.

Going forward: Each annual NDG-10 revision will be re-mapped and the gap published.

Data Processing Addendum framework

How we contract for PHI

We operate as a data processor. Each deploying hospital is the data controller for its patients' data. This split is captured in the DPA attached to every customer contract.

Split of responsibilities

Article 28-style flow-down (where applicable)

Every sub-processor that processes PHI on our behalf has, at minimum: confidentiality obligations on its personnel, equivalent or stronger security controls than ours, sub-processor list disclosure to us with notification of changes, audit/inspection rights (typically via SOC 2 / ISO 27001 reports), data-subject rights support, and breach notification within a time window aligned with our customer obligations.

Sub-processors

Who else processes PHI on our behalf

Sub-processor Purpose Region DPA
Fly.ioApplication runtime (cloud deployment)EU (Frankfurt) default; region pin availableSigned
CloudflareCDN, WAF, DDoS — network metadata onlyGlobal edgeSigned
Backblaze B2Off-host backup + audit chunk storage (client-side encrypted)EUSigned
ResendOutbound transactional emailEUSigned
SentryError reporting with PHI-scrubbed eventsEUSigned
AnthropicAI features (per-tenant opt-in only)Per-APISigned

For per-hospital server and on-premise deployment models, the cloud sub-processor list is reduced — Fly and Cloudflare may not apply if the deployment is in your own data centre. Backblaze remains (for off-host backup) unless you've configured an alternative. Sentry, Resend and Anthropic remain regardless of deployment model unless explicitly disabled at your tenant level.

Cross-border data transfer

Where your patients' data lives

By default, customer data is stored in EU regions (Fly Frankfurt for live data, Backblaze EU region for off-host backup). Region pinning is available at Enterprise tier — Singapore (APAC), Sydney (Australia), Johannesburg (South Africa), São Paulo (Latin America). For hospitals in jurisdictions with strict data-locality rules, the per-hospital server install or on-premise deployment puts data physically in your facility.

Per-jurisdiction posture

Retention

How long we keep what

Class Retention
Live PHILifetime of patient relationship + per-jurisdiction medical-records retention (typically 7–10 years post last contact)
Audit chain7 years in immutable off-host storage (B2 Object Lock Compliance mode)
Snapshots (hourly)48h hot + 28 daily local + 90d off-host hide + 30d off-host delete
Sentry events90 days (PHI-scrubbed)
Session records2 hours (rolling)
Public marketing logs30 days

Want to walk through this with your compliance officer?

Book a 30-minute call. We'll review the relevant standards for your jurisdiction, walk through the DPA / BAA template, and answer the questions your compliance team raises.

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